Privacy Policy

This privacy policy Instructions (hereinafter referred to as the "privacy policy ") are used to explain the use of Homeee (Thailand) Co., Ltd. and its subsidiaries, affiliates and other companies under the same brand (collectively, "we") in your use of the The Homeee application and website operated by Homeee ("APP" or "Website", respectively) collect, use, process and disclose you in the course of all products, features and services (collectively, "Services") worldwide personal data.

This privacy policy applies to customers, distributors, merchants, suppliers, partners (for example: agents (real estate brokers who join us) and real estate developers), contractors and service providers (collectively, "you").

We recognize the importance of personal data and other information about you. so you can be confident that we are transparent and responsible for collecting Use or disclose your information in accordance with the Personal Data Protection Act B.E. 2562 ("Personal Data Protection Act") and other relevant laws. Privacy Policy This has been made to explain to you the details of the collection.

"Personal data" means any information that can be used to identify you or to identify you personally from that information. This includes, but is not limited to, your name, nationality, phone number, bank and credit card details, personal preferences, email address, your photo, government issued ID number, biometric information, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment and financial status information, and more.

We will collect, use, disclose or process your personal data in accordance with this privacy policy on the applicable legal basis or on the basis of your consent, such as:

• it is required for us to enter into or perform a contract with you.
• To protect our or the legitimate rights and interests of others.
• including but not limited to the purposes set forth in this privacy policy.

“Sensitive Personal Data” means personal data as provided for in Section 26 of the Personal Data Protection Act B.E2562. health information, disability, trade union information Genetic data,

biological data or any other data which affects the owner of personal data in a similar manner as specified in the notification of the Personal Data Protection Committee.

“Processing personal data” means any processing of personal data, such as collecting, recording, copying, organizing, keeping, updating, changing, using, recovering, disclosing, forwarding, disseminating, transferring, merging, deleting, destroying, etc.

“Personal Data Subject” means the natural person who owns the personal data that we collect, use or disclose.

“Personal Data Controller” means a person or juristic person who has the authority to make decisions about the collection, use or disclosure of personal data.

“Personal Data Processor” means a person or juristic person who performs the collection, use or disclosure of Personal Data on the order or on behalf of the Personal Data Controller.

Ⅰ.Collection of Personal data

We will collect your personal data in the following ways:

You provide us with your personal data

We will collect personal data about you that you provide to us. For example, when you do the following:

• You fill out a user profile or application form (for example: your name, contact and identification information).
• Information you provide to evaluate your eligibility to provide services as an agency partner (for example: driver's license information, ID information, and background check results).
• The social media you contact us (for example, social media accounts, personal photos and other public information).
• Your participation in a contest or event organized by us (for example: a photo, audio or video you submit, which may include a photo of yourself).
• Your real-name verification through various mediums (for example: social media login verification, submitting your photo or third-party verification of your payment card information).
• Your fill up demographic information in surveys (such as age, gender, and other information you voluntarily provide, such as marital status.

When you use our services

Personal data may be collected through the normal operation of our applications, websites and services, such as:

• Your location.
• Feedback, Comment and Suggestion.
• Transaction Information (Example: Payment Method).
• Contact information between you and our app, website, or service (for example: feature usage or viewing content).
• Device information (for example: device model and serial number, IP address, file name, application name and version, GPS location, IMEI number and advertising identifier, or other information indicating modification, device or application (modification).
• Personal data you provide through the use of the communication features on our apps; and possibly through audio and/or video messages (such as pictures, audio or both) and other relevant messages in the real estate sales process between you and us and our distributors.

APP or Device

• Your personal data may be recorded in this audio and/or video. In the case of audio and/or video recordings, such audio and video will be collected, processed, used and stored in accordance with this privacy policy and relevant applicable law.

Please be aware that our partners may have photographic records. Or view a video during a personal necessities property, which may result in your personal data being stored and recorded by our partners during your use of our services. However, we do not encourage or prohibit partners from using apps or personal devices while viewing properties. The collection, use or disclosure of any personal data you obtain from such personal applications or devices is the sole responsibility of that partner. If you have questions about the use of the app or device, you can ask the relevant partner for more details.

Via other sources

We collect your personal data, such as your name, contact information, and where necessary to obtain your identifying information from other sources, including:

Referral Program (referral)

• Our business partners, e.g. developers, payment service providers.
• Insurance and financial services providers.
• Credit bureaus, other credit information companies, and credit reporting agencies.
• Publicly available repositories or government repositories.
• When another users marks you as an emergency contact.
• When other users mark you as a recipient or beneficiary of using our services.
• When you have a conversation in our app.
• Marketing service provider or partner.

Sensitive Personal data

in general The Company does not collect sensitive personal data that is restricted by any privacy law. in the provision of services unless specifically requested by us. Please refrain from sending or providing any sensitive personal data to the Company while using the Service. Your disclosure of any sensitive personal data will be deemed to have provided your prior consent for the Company to process that personal data. Regardless of the purpose you have provided that information.

When you provide us with personal data of others

In certain circumstances, you may provide us with personal data about others, such as your spouse, family or friends. For example, you may add them as emergency contacts, or when chatting in our applications, or you may add them as recipients or beneficiaries using our services; if you provide us with personal data about others, you represent and warrant that you have obtained the consent of the above-mentioned other parties for our collection, use and disclosure of their personal data in accordance with this privacy policy.

Minor personal data

You, as a parent or legal guardian, do not allow the minor under your guardianship to provide Homeee with his personal data. If the personal data of the above-mentioned minors is disclosed to us, we will be deemed to have accepted and agreed to us to process the personal data of such minors, who will be bound by this privacy policy and be responsible for their actions.

Ⅱ. Use of Personal data

We may use, collect and process your personal data for the following purposes set out in the list below (collectively, the "Purposes"). In addition, if you use Homeee's services in various ways, (for example: if you use multiple Homeee-provided services or you are both an agent and a user), we may collect and associate your personal data to facilitate your use of our services and for the following purposes:

Provide services and functions

Your personal data may be used to provide, improve, maintain and develop our applications, websites and services, including using your personal data to:

• Transmit your name and phone number to our partners to provide you with consulting or intermediary services related to real estate purchases and leases.
• Create, manage and keep your account up to date.
• Process, manage or verify your eligibility to receive or apply for services, promotions, rewards and subscriptions to Homeee.
• Review historical data, risk assessment and analysis.
• Verify your identity and age information (if necessary).
• Review your sales application and process your payment.
• Provide, accept, arrange or assist insurance and financial services.
• Follow up on your sales progress.
• Improve your app experience (for example, recommend products and services that are right for you, or specify your needs to improve it to suit your experience with Homeee).
• To help make your experience smoother, for example: auto-filling registration information (eg: your name or phone number), automatically transferring the above information from one service to another, or when you participate in our research.
• Internal management is necessary to provide our services, such as resolving software bugs (bugs) and operational issues, data analysis testing and research, operational tracking and analysis, and activities.
• To ensure the safety and efficiency of the service and the facilities or equipment used to provide the service.
• Open the communication channel between users and us.
• Invite you to participate in our surveys and research.
• Services are provided when you authorize a personal data processor (for example: an organization from which you purchased goods or services or an organization provided by Homeee).

Security and safty

We use your data to ensure the safety and security of our services and all users of our services, including:

• Identify unsafe sales practices such as fraudulent sales, inappropriate advertising.
• Identify yourself when logging into Homeee.
• Use device information, location, history, usage and other personal data to prevent, detect and combat fraudulent or unsafe activities.
• Monitor compliance with our terms, conditions and policies.

User support

We use personal data to troubleshoot problems or perform customer support tasks. We may pass the following

• Investigate and manage user issues.
• Track and develop or respond to customer support.
• Answer questions, provide comments and feedback.
• Inform you of steps to resolve customer support issues.

Research and development of new features and services

We may use your personal data for testing, research, analysis and product development so that we can understand and analyze your needs and preferences, protect your personal data, develop and improve the security and stability of our services, develop new features products and new services for the development of such as insurance and financial services.

Legal Purpose

We may use the personal data we collect for the legal purpose, such as to investigate and resolve claims or disputes, or as permitted or required by applicable law.

We may use your personal data as necessary, in consultation with domestic and international legal advisors or legal authorities, governments or other government agencies that have been advised, expected or required to do so;

For example, we may use your personal data. To:

• Comply with court orders or legal, governmental or other government agencies.
• Enforce terms and conditions or our other agreements.
• Protect our rights or property in the event of a claim or dispute.

Marketing and Promotion

We may use personal data to provide marketing communications for products or services relevant to your interests (of interest or in relation to personal data).We may send you our partners, sponsors and advertising or promotional products. We can do the following:

• To send you special offers on all homeee services that interest you or are relevant to you.
• To send reminders, newsletters, updates, mailings, promotional materials, special benefits, special occasion wishes.
• To notify, invite and arrange your participation in events organized by us.

We may communicate marketing and promotional messages through various appropriate means (including via text messages, messaging apps (e.g. WhatsApp, Telegram, LINE, Viber, WeChat)), in-app notifications, phone calls and emails

We may communicate marketing and promotional messages through various appropriate means (including via text messages, messaging apps (e.g. WhatsApp, Telegram, LINE, Viber, WeChat)), in-app notifications, phone calls and emails

If you wish to opt out of marketing communications ，please notify us that . We would like to inform you that Homeee may send you basic messages related to our services (such as information about deals, points, rewards, etc.) even if you choose not to receive marketing or promotional information.

Post user content

If you post content (such as comments or reviews) on the Homeee platform. This content will be published with your personal data (such as your profile name, uploaded pictures) and other information you collect in your content.

Ⅲ. Disclosure of Personal data

We are obliged to provide personal data to multiple parties for the purposes described in Article 2 (Use of Personal Data), including the following parties:

Other Users

For example:

• If you are a home buyer, we may provide the user's name , phone number,E-mail address and buying intention information collected with your permit.
• If you are an agent, we may provide your personal data, including your name ， photo，work experience etc.
• If you use our in-app communication service (chat), we may disclose your registered phone number and name with Homeee to others with whom you communicate.

Third-party

Third parties in connection with your use of Homeee services.

For example:

• If you are a home buyer, we may apply for a loan for you by sending your information to a financial institution to request a loan.

The owner of the Homeee account you are using.

For example:

• The real estate company you belong to may receive information about your sale.

With subsidiaries and affiliates

We provide personal data to subsidiaries. Related companies, companies under common control and affiliates, our affiliates share shared resources such as infrastructure and technology. To provide you with a consistent, relevant and secure experience when using our services and for the purposes set out in this privacy policy.

• For example, we do this to make your experience smoother, for example, when you register for a new Homeee service, your registration information for using the Homeee service is automatically filled in.

With service providers and Homeee business partners

We may provide your personal data to service providers, consultants, marketing partners, research companies and other service providers or business partners, including:

• Payment assistance and assessment service providers.
• Collection service providers.
• Credit bureaus, other credit information companies and other credit reporting agencies Background check service providers and anti-money laundering services.
• Cloud storage service providers (cloud).
• Media, marketing and Platform Provider Partners.
• Data Analytics Service Providers.
• Insurance and Financial Partnerships Partners.
• Asset Managers and Custodians.
• Authentication Service Providers.

For example:

• If you request services through Homeee partners or use Homeee partners' promotions. Homeee may share your personal data with Homeee's partners.

With our legal counsel and government agencies

We may provide your personal data to our legal advisors, government agencies and other third parties for the purposes of carrying out legal purposes (as described above) or in the following circumstances

• When necessary to address an emergency that threatens human life, health, or safety.
• When required by the public interest (eg, in a public health emergency, to conduct contact tracing; and to protect our community)

Business transfer

We may disclose your personal data to third parties through acquisition, sale, holding, joint venture, merger, reorganization, financing, or any other type of business transaction. However, your personal data will continue to be subject to our obligations as set out in the privacy policy you previously signed.

Ⅳ. Retention of Personal data

We will retain your personal data for as long as is necessary for the purposes described in this policy, unless we are required or permitted by law to retain it for a longer period of time. When your personal data is no longer required for our services or purposes, or when we do not have a legal or business purpose to keep your personal data, we will delete, destroy, anonymize, or block outgoing personal identifiable information as required by applicable law access or use your personal data for any purpose other than complying with this policy.

Ⅴ. International transfers of personal data

Your personal data may be transferred from the country, state, and city where you live while using our Services ("home country") to other countries, states and cities ("Alternate Countries").

When we transfer your personal data from your home country to Alternate County, we will comply with legal obligations with regard to your personal data, including having a legal basis to allow the transfer of personal data. We will also take steps to ensure recipients in other countries have data protection obligations commensurate with the standards of protection required by applicable law.

Our legal basis is consent (For example, when you provide personal data, we may ask for your consent to transfer your personal data from your home country to Alternate Countries) or to take other safeguards.

Depending on your location, the transfer or transfer of information may involve transmission and storage in countries other than your home country. In the event of any data transfer or transfer, you can view the relevant section of this document or consult us.

Your usage data will be securely stored in Singapore, where Homeee hosts its core infrastructure. We have complied with the Personal Data Protection Act of Thailand B.E. 2562 (2019) and have granted the rights required by law.

Although some personal data is hosted outside of Thailand, we will continue to adhere to appropriate data protection measures and select data centres with the highest standards of protection and availability, as we could not find any compliant data centres in Thailand. Therefore, we need to host our core infrastructure in Singapore for the recovery facility, while some personal data for billing will be stored and processed in Thailand.

Ⅵ. Cookies policy

Based on your use of the website and applications, Homeee and its third-party partners may use cookies, web beacons, tags, scripts, local shared objects, such as HTTP, HTML5 and Flash (sometimes referred to as "flash cookies"), advertising identifiers and similar technologies ("cookies"). Cookies may be retained and stored on your browser or personal device only for a certain period of time.

Cookies may contain unique identifiers and are stored on your computer or mobile device, in emails we send you, and elsewhere on our web pages, and are used for a variety of purposes, such as:

• Provide basic functionality required to use our website, services or applications.
• Authenticate you or remember your settings and user preferences.
• Display and evaluate the effectiveness of advertising campaigns, such as counting page-views or click-through rates.
• Network traffic analysis and traffic trends.
• To serve you relevant advertisements on other applications and websites. (whether we or other advertisers).
• To improve the user interface and experience by understanding the online behavior and interests of users who typically interact with our websites, services or applications.

Homeee may allow third parties to use cookies on websites and applications to collect personal data for the same purposes that Homeee collects for itself. Third parties may be able to correlate personal data collected by themselves with other personal data about you obtained by third parties from other sources. We cannot access or control the unnecessary use of cookies by third parties.

Disable cookies on our website

You have the right to choose to disable, block or stop using cookies. Homeee would like to inform you that if you refuse or delete certain cookies, the above disabling of such cookies will affect the availability, functionality or use of our website, services or applications.

You can adjust your internet browser settings to suppress blocking or disable cookies and delete your browsing history or cache from your internet browser. Settings may be located in the History, Preferences, Settings, or Privacy section of your Internet browser. You can consult the help section on your Internet browser for more information.

Disable targeted advertising on other platforms

We may assist in displaying targeted advertising on other platforms, such as other online platforms where you may be a user of the Services.

Depending on the type of phone and software, you can adjust your settings through the Homeee app to prevent Homeee from using your personal data to display advertisements that may be relevant or relevant to you. The actions you are currently using, you can choose to disable mobile metrics and the ability to track through other company-owned apps and websites. By adjusting the settings available on your mobile device, from resetting, deleting, restricting and/or prohibiting the use of such movement indicators.

Although we do not use your personal data to display advertisements that may be relevant or relevant to you on other platforms, you may still see generic advertisements that may be relevant to you. This is because we work with third-party advertisers or platforms to deliver advertisements to service users with features or characteristics that match their personal interests, and you can restrict viewing of these advertisements through the settings on the respective platforms.

Ⅶ. Personal data Protection

We will take legal, organizational and technical measures to ensure that your personal data is protected. This includes measures to prevent unauthorized loss or use or access to personal data. We limit our employees' access to your personal data and any processes related to that personal data on a need-to-know basis. This can be done with permission and your personal data must be kept confidential.

Ⅷ. Your rights to your personal data

Subject to applicable law, you have the following rights:

• Access your personal data and obtain a copy of your personal data.
• Request correction and/or deletion of your personal data .
• Request a suspension or object to the processing of your personal data .
• Withdraw you Consent authorization to process your personal data (when we process your personal data based on your consent).
• Using automated tools or devices to obtain or request the transfer of your personal data to another organization in a readable or generally available format. This is the personal data you provide to us and we use your personal data for the purposes of consent or performance of a contract.
• If your privacy rights have been violated or if you have been harmed by unlawful processing of your personal data, you can Personal Data Supervisor Complaints.

While you can choose whether to provide us with personal data, you can choose not to provide that information to us. If we ask for your consent to our processing of your personal data and you have subsequently chosen to withdraw your consent, we will respect your decision and comply with our legal obligations.

However, choosing not to provide us with your personal data, withdrawing consent to the use of your personal data, or withdrawing the terms of this privacy policy may prevent us from providing you with the information described in Section II (Use of Personal Data), necessary services for the purpose of use of personal data described above, or may cause you to be unable to use the applications and services.

When you withdraw your consent, we are still able to process your personal data to the extent required or permitted by applicable law.

We will first review and confirm your request. We may ask you to provide information or supporting documents related to your request to identify and/or confirm your right to request an exercise.

Once you have confirmed your right to request the exercise of your rights, we will comply with that request within the period specified by applicable law.

Ⅸ. Changes and Updates

Homeee reserves the right to change, update or modify the terms of this privacy policy at any time, and any revised version of this policy will be effective immediately upon posting of the revised policy. Homeee will notify you of any material changes in the way we process personal data. In case of changes, we will revise the latest date at the bottom of this page. We may notify you in other ways, such as the contact information you provide, as appropriate. We will also post an updated version of the privacy policy on our website https://www.homeee.com. If you continue to use the app, website, service or contact Homeee after the effective date, you are deemed to have accepted the above changes, updates or modifications to the privacy policy.

Ⅹ. Contact Us

Personal data owners can contact us as follows:

725 S-Metro building, 12th Floor 1201 Room,Sukhumvit Road, Khlong Tan Nuea Sub-District,Wattana District, Bangkok 10110.

TEL: 02-261-5888

Email : support@homeee.com

This policy was last revised and effective as of June 1, 2022.