Privacy Policy

Vivera Solutions Co., Ltd. (“Vivera”, “we”, “us”, or “our”) respects the privacy of our customers and users and is committed to handling personal data responsibly and in accordance with applicable data protection laws.

This Privacy Policy explains how Vivera collects, uses, discloses, stores, transfers, and otherwise processes personal data when you access or use our websites, online stores, applications, subdomains, customer accounts, products, services, communications, and other services operated by or on behalf of Vivera (collectively, the “Services”).

This Privacy Policy also explains the choices and rights that may be available to you in relation to your personal data.

Please read this Privacy Policy carefully before creating a Vivera Account or using our Services.

PART I — GENERAL

1. WHO WE ARE

Vivera Solutions Co., Ltd. operates an online commerce platform through which customers may purchase physical and digital products.

For purposes of applicable data protection law, Vivera is generally responsible for determining the purposes and means by which personal data collected through our Services is processed.

Our service providers may process personal data on behalf of Vivera or, depending on the circumstances and applicable law, may process certain information independently under their own privacy policies and legal obligations.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data processed in connection with:

• Vivera websites;

• Vivera online stores;

• Vivera applications;

• Vivera subdomains;

• customer accounts;

• account registration;

• KYC and verification processes;

• online purchases;

• payment processing;

• digital Product fulfilment;

• physical Product delivery;

• customer-support enquiries;

• website contact forms;

• email communications;

• LINE communications;

• WhatsApp communications;

• promotional communications;

• fraud-prevention and transaction-review activities;

• website analytics; and

• other Vivera Services that refer to this Privacy Policy.

Third-party services, websites, platforms, games, payment providers, logistics companies, and other independent services may maintain their own privacy policies.

Their independent handling of personal data is governed by their own applicable privacy practices.

PART II — PERSONAL DATA WE COLLECT

3. ACCOUNT INFORMATION

A Vivera Account is required to place an Order.

Vivera does not currently provide guest checkout.

When you create or use a Vivera Account, we may collect or process information including:

• email address;

• authentication credentials;

• Account ID;

• Account status;

• Account preferences;

• registration date;

• login and authentication information;

• Account activity;

• verification status; and

• information you provide when managing or updating your Account.

Customers are responsible for keeping their Account information accurate and current.

4. CONTACT INFORMATION

Depending on how you use Vivera, we may collect:

• full name;

• email address;

• telephone number;

• billing address;

• shipping address;

• country or region; and

• other contact information voluntarily provided to us.

5. ORDER AND TRANSACTION INFORMATION

When you place or attempt to place an Order, we may collect, generate, or receive information including:

• Order number;

• Product purchased;

• Product quantity;

• Product denomination;

• transaction amount;

• transaction currency;

• Order date and time;

• payment status;

• verification status;

• fulfilment status;

• shipping status;

• delivery status;

• transaction reference;

• refund status;

• cancellation status;

• dispute information;

• chargeback information; and

• other information necessary to process or manage the Order.

We may maintain transaction records for purposes including Order fulfilment, customer support, accounting, security, fraud prevention, dispute handling, and legal compliance.

6. PAYMENT INFORMATION

Payments through Vivera may be processed by third-party Payment Providers, which may include payment gateways, banks, financial institutions, card networks, wallet providers, or other payment-processing services.

Customers may provide payment credentials directly to the relevant Payment Provider.

Where payment credentials are processed directly by a Payment Provider, Vivera does not intend to store full payment card numbers, card security codes, or equivalent sensitive payment credentials.

Vivera may nevertheless receive information from Payment Providers that is necessary to manage the transaction.

This may include:

• payment status;

• transaction identifier;

• transaction amount;

• payment method type;

• payment confirmation;

• payment failure information;

• refund information;

• chargeback information;

• dispute information;

• fraud alerts;

• transaction-risk results;

• verification results; and

• other information reasonably required to process or investigate the transaction.

Payment Providers may process payment information in accordance with their own privacy policies, security requirements, and legal obligations.

PART III — DIGITAL AND PHYSICAL FULFILMENT DATA

7. DIGITAL PRODUCT INFORMATION

Certain Digital Products require information relating to a customer's game, account, platform, service, or other fulfilment destination.

Depending on the Product, Vivera may collect information including:

• player ID;

• game ID;

• server ID;

• character ID;

• platform;

• region;

• country;

• account identifier;

• email address;

• telephone number where specifically required;

• Product denomination; and

• other Product-specific information required for fulfilment.

The exact information required depends on the Product purchased.

8. INFORMATION SHARED FOR DIGITAL FULFILMENT

Vivera seeks to provide Suppliers and Fulfilment Partners only with the information reasonably necessary to complete the relevant Order.

For example:

If a Direct Top-Up requires only a player ID and server ID, Vivera does not intend to provide unrelated personal information such as the customer's shipping address.

If a Product requires an email address for fulfilment, the required email address may be provided to the relevant Supplier or Fulfilment Partner.

We may also provide:

• Order reference information;

• Product information;

• denomination;

• fulfilment destination;

• region;

• platform; and

• other information specifically required to complete or investigate the Order.

Vivera does not intend to provide Suppliers with additional customer information that is unnecessary for fulfilment.

9. PHYSICAL PRODUCT DELIVERY INFORMATION

When you purchase a Physical Product, Vivera may collect and process information necessary to arrange delivery.

This may include:

• recipient name;

• shipping address;

• telephone number;

• Order number;

• Product information;

• shipment information; and

• tracking information.

Necessary information may be provided to:

• courier companies;

• logistics providers;

• Suppliers;

• warehouses;

• fulfilment providers; and

• other parties reasonably involved in preparing or delivering the Order.

Vivera seeks to provide these parties only with information reasonably necessary for delivery and related services.

PART IV — CUSTOMER SUPPORT

10. CUSTOMER SUPPORT INFORMATION

Customers may contact Vivera through channels including:

• website contact forms;

• email;

• LINE;

• WhatsApp; and

• other official Vivera support channels made available from time to time.

When you contact us, we may collect and process:

• your name;

• contact information;

• Account information;

• Order number;

• details of your enquiry;

• messages and communications;

• screenshots;

• attachments;

• complaint information;

• refund or cancellation information;

• payment-dispute information; and

• information necessary to investigate or respond to the matter.

Customer-support communications may be retained where reasonably necessary for customer service, dispute resolution, fraud prevention, security, quality control, and legal or compliance purposes.

Customers should not send passwords or unnecessary sensitive information through customer-support channels.

PART V — KYC AND VERIFICATION

11. IDENTITY VERIFICATION AND KYC

Vivera may use identity verification, Know Your Customer (“KYC”), Know Your Business (“KYB”), or related verification procedures.

Verification may be required in circumstances including:

• Account verification;

• unusually large Orders;

• high-risk Products;

• unusual transaction activity;

• Payment Provider alerts;

• suspected fraud;

• Business Customer onboarding;

• applications for increased purchasing limits;

• payment disputes;

• security investigations; or

• legal or regulatory requirements.

Where verification is required, Vivera may request additional information reasonably necessary to complete the relevant process.

The exact information required may depend on the nature of the Account, transaction, risk, and verification process.

Where Vivera introduces a third-party identity verification provider, additional information about the relevant provider or processing may be provided when appropriate.

Customers should submit verification information only through official Vivera channels or approved verification systems.

12. BUSINESS CUSTOMER VERIFICATION

Business Customers seeking higher-volume, wholesale, reseller, API, customized, or other enhanced purchasing arrangements may be required to provide information including:

• company name;

• company registration information;

• business contact information;

• authorized representative information;

• ownership or control information where required;

• identification information;

• supporting documents; and

• other information reasonably required for KYC, KYB, compliance, or risk assessment.

The exact requirements may depend on the business arrangement and applicable compliance requirements.

PART VI — INFORMATION WE RECEIVE FROM OTHER PARTIES

13. PAYMENT PROVIDERS

Vivera may receive information from Payment Providers including:

• payment confirmation;

• payment status;

• transaction ID;

• refund status;

• chargeback information;

• dispute information;

• fraud indicators;

• risk results;

• verification results; and

• other information necessary to process or investigate payments.

14. SUPPLIERS AND FULFILMENT PARTNERS

Vivera may receive information from Suppliers and Fulfilment Partners including:

• Product availability;

• fulfilment status;

• Direct Top-Up confirmation;

• code-delivery information;

• failed fulfilment information;

• Supplier transaction reference;

• Product-status information; and

• information reasonably necessary to investigate fulfilment issues.

15. LOGISTICS PROVIDERS

For Physical Products, Vivera may receive information from couriers and logistics providers including:

• shipment status;

• tracking information;

• delivery status;

• delivery confirmation;

• failed delivery information;

• return information; and

• information necessary to investigate delivery issues.

PART VII — TECHNICAL DATA AND ANALYTICS

16. INFORMATION COLLECTED AUTOMATICALLY

When you use Vivera's websites or online Services, certain technical and usage information may be collected automatically.

This may include:

• IP address;

• device information;

• browser information;

• operating system;

• website activity;

• pages viewed;

• session information;

• access date and time;

• referring website or source;

• technical logs;

• cookie identifiers; and

• information relating to interaction with the Services.

This information may be used for website operation, security, performance monitoring, troubleshooting, analytics, fraud prevention, and Service improvement.

17. GOOGLE ANALYTICS

Vivera uses Google Analytics to help understand website usage and performance.

Google Analytics may process information relating to how visitors use our websites and Services.

Vivera may use analytics information to:

• understand website traffic;

• measure website performance;

• understand how users interact with the website;

• identify technical problems;

• evaluate page performance;

• improve user experience; and

• improve Vivera's Services.

Google may process information in connection with providing its analytics services according to Google's own applicable privacy terms and policies.

Where required by applicable law, Vivera may use appropriate cookie or consent controls for analytics technologies.

18. COOKIES AND SIMILAR TECHNOLOGIES

Vivera and our service providers may use cookies and similar technologies.

These technologies may be used for purposes including:

• Account login;

• authentication;

• session management;

• shopping-cart functionality;

• security;

• fraud prevention;

• website preferences;

• technical operation;

• website analytics; and

• performance measurement.

Some cookies may be necessary for the operation of the Services.

Other cookies, including certain analytics technologies, may be subject to consent or preference controls where required by applicable law.

Vivera may provide additional information through a cookie notification, cookie settings interface, or separate Cookie Policy.

PART VIII — HOW WE USE PERSONAL DATA

19. PROVIDING VIVERA SERVICES

Vivera may process personal data to:

• create and maintain Accounts;

• authenticate Customers;

• manage Account access;

• process Orders;

• verify payments;

• manage payment status;

• fulfil Digital Products;

• process Direct Top-Ups;

• arrange delivery of Physical Products;

• provide Order information;

• manage refunds;

• process cancellations; and

• maintain transaction records.

20. CUSTOMER COMMUNICATIONS

We may process personal data to:

• send Account notifications;

• confirm Orders;

• provide payment-status updates;

• provide verification updates;

• provide Digital Product fulfilment notifications;

• provide shipping notifications;

• provide refund or cancellation information;

• answer enquiries;

• respond to complaints;

• provide customer support; and

• communicate important changes relating to our Services.

21. FRAUD PREVENTION AND SECURITY

Vivera may process personal data and transaction information to:

• identify suspicious transactions;

• prevent unauthorized payments;

• detect Account abuse;

• protect Customer Accounts;

• prevent promotion abuse;

• investigate fraud;

• investigate chargebacks;

• assess transaction risk;

• cooperate with Payment Providers;

• manually review flagged transactions;

• request additional verification; and

• protect Vivera, Customers, Suppliers, and other service providers.

22. SERVICE IMPROVEMENT AND ANALYTICS

Vivera may process data to:

• understand Service usage;

• evaluate website performance;

• troubleshoot technical problems;

• improve website functionality;

• improve customer experience;

• improve customer support;

• understand Product demand; and

• improve or develop Vivera Services.

23. LEGAL AND COMPLIANCE PURPOSES

Vivera may process personal data where reasonably necessary to:

• comply with applicable legal obligations;

• maintain required accounting or business records;

• comply with tax requirements;

• respond to lawful requests;

• cooperate with competent authorities;

• respond to regulatory requirements;

• establish, exercise, or defend legal claims;

• handle payment disputes;

• respond to chargebacks;

• investigate suspected unlawful conduct; and

• protect Vivera's legal rights.

PART IX — LEGAL BASES FOR PROCESSING

24. PERFORMANCE OF A CONTRACT

Where applicable, Vivera may process personal data because processing is necessary to perform or take steps relating to a contract with the Customer.

Examples may include:

• creating and maintaining an Account;

• processing an Order;

• confirming payment;

• fulfilling a Digital Product;

• completing a Direct Top-Up;

• shipping a Physical Product; and

• providing transaction-related support.

25. LEGAL OBLIGATIONS

Vivera may process or retain information where necessary to comply with applicable legal, regulatory, tax, accounting, compliance, or other obligations.

26. LEGITIMATE INTERESTS

Where permitted by applicable law, Vivera may process personal data where reasonably necessary for legitimate interests such as:

• fraud prevention;

• security;

• protection of Accounts;

• Service improvement;

• transaction administration;

• dispute management;

• enforcement of contractual rights;

• maintenance of business records; and

• protection of Vivera's legal interests.

Where required, Vivera will consider the rights and interests of the affected individual when relying on legitimate interests.

27. CONSENT

Where applicable law requires consent for a particular processing activity, Vivera may request consent before conducting that activity.

Where processing relies upon consent, Customers may be entitled to withdraw that consent.

Withdrawal of consent does not affect processing lawfully carried out before the withdrawal.

PART X — TRANSACTION MONITORING AND FRAUD REVIEW

28. TRANSACTION RISK INFORMATION

Payment Providers and other security systems may provide or generate information indicating that a transaction may require additional review.

This may include:

• fraud alerts;

• transaction-risk results;

• security indicators;

• payment verification results; and

• other relevant risk information.

29. MANUAL REVIEW

Transactions that are flagged as unusual or high risk may be manually reviewed by Vivera's team.

Vivera may work with the relevant Payment Provider during an investigation.

An Order may be temporarily held while an investigation is conducted.

A fraud or risk alert does not automatically mean that the Customer has committed wrongdoing.

30. ADDITIONAL CUSTOMER VERIFICATION

Vivera may request additional information where reasonably necessary to verify:

• a Customer;

• an Account;

• a payment;

• a high-value transaction;

• a high-risk Product;

• unusual Account activity; or

• another transaction presenting reasonable security concerns.

Information requested should be limited to what is reasonably necessary for the relevant verification process.

If verification cannot be completed, Vivera may be unable to process or fulfil the applicable Order.

PART XI — MARKETING COMMUNICATIONS

31. PROMOTIONAL COMMUNICATIONS

Vivera may send Customers information relating to:

• promotions;

• special offers;

• discounts;

• campaigns;

• new Products;

• Product recommendations;

• deals; and

• other Vivera commercial information

where permitted by applicable law.

Promotional communications are separate from communications necessary to manage an Account or Order.

32. TRANSACTIONAL COMMUNICATIONS

Vivera may send non-promotional communications necessary for providing or managing the Services.

These may include:

• registration information;

• Account notifications;

• security alerts;

• verification requests;

• Order confirmations;

• payment confirmations;

• payment-status updates;

• fulfilment updates;

• delivery notifications;

• refund information;

• cancellation information; and

• other important Service communications.

Customers may continue to receive necessary transactional communications even if they opt out of promotional marketing.

33. MARKETING OPT-OUT

Where Vivera sends promotional communications, Customers may opt out through:

• an unsubscribe function provided in the communication;

• Account settings where available; or

• Vivera's official support channels.

Vivera may retain limited information necessary to record and respect a Customer's marketing preference.

PART XII — SHARING PERSONAL DATA

34. GENERAL

Vivera does not intend to sell or indiscriminately disclose customer personal data.

Vivera may share personal data where reasonably necessary for operating the Services, fulfilling Orders, processing payments, maintaining security, complying with applicable law, or protecting legitimate rights.

35. PAYMENT PROVIDERS

Information may be shared with Payment Providers for purposes including:

• payment processing;

• transaction authorization;

• payment verification;

• fraud prevention;

• refunds;

• chargebacks;

• payment disputes; and

• transaction investigations.

36. SUPPLIERS AND FULFILMENT PARTNERS

Vivera may provide Suppliers and Fulfilment Partners with information reasonably necessary to:

• fulfil Digital Products;

• perform Direct Top-Ups;

• provide Digital Codes;

• confirm fulfilment;

• investigate failed fulfilment;

• investigate Product problems; or

• complete other necessary Product-related services.

Vivera seeks to minimize the amount of personal data provided to Suppliers.

37. LOGISTICS PROVIDERS

Vivera may provide necessary information to logistics providers for:

• shipping;

• tracking;

• delivery;

• delivery confirmation;

• failed delivery management;

• returns; and

• delivery-related support.

38. CLOUD AND TECHNOLOGY SERVICE PROVIDERS

Vivera may use technology service providers to support:

• website hosting;

• cloud infrastructure;

• databases;

• data storage;

• backups;

• cybersecurity;

• communications;

• website operation; and

• other technical functions.

These providers may process personal data where necessary to provide their services to Vivera.

39. AMAZON WEB SERVICES

Vivera uses Amazon Web Services (“AWS”) cloud services in connection with hosting, storing, processing, securing, or operating data and infrastructure used by the Services.

The specific AWS services and processing locations may depend on Vivera's technical configuration and infrastructure.

Vivera may modify its cloud infrastructure or use additional providers as its systems develop.

40. ANALYTICS PROVIDERS

Vivera may provide or allow access to certain technical and website-use information by analytics providers such as Google Analytics for purposes relating to website performance, usage measurement, and improvement.

41. COMMUNICATION SERVICE PROVIDERS

Personal data may be processed through third-party communication platforms used by Customers or Vivera, including email, LINE, WhatsApp, and website communication systems.

Where Customers use an independent communication platform, that platform may also process information according to its own privacy practices.

42. PROFESSIONAL ADVISERS

Where reasonably necessary, Vivera may disclose information to professional advisers including:

• lawyers;

• accountants;

• auditors;

• insurers;

• compliance advisers; and

• other professional service providers.

43. GOVERNMENT AND AUTHORITIES

Vivera may disclose personal data to governmental, regulatory, judicial, law-enforcement, or other competent authorities where:

• required by applicable law;

• required by a valid legal process;

• necessary to comply with lawful regulatory requirements;

• necessary to investigate unlawful conduct; or

• otherwise permitted by applicable law.

PART XIII — DATA MINIMISATION

44. MINIMUM NECESSARY INFORMATION

Vivera seeks to collect, process, and disclose only information reasonably necessary for the relevant purpose.

For Digital Product fulfilment, Vivera seeks to share only the information required to complete or investigate the particular Order.

For example, where a Supplier requires only a player ID and server ID, unrelated shipping information should not normally be provided to that Supplier.

PART XIV — INTERNATIONAL PROCESSING AND TRANSFERS

45. GLOBAL SERVICES

Vivera may provide Services to Customers located in different countries.

Vivera also works or may work with:

• Payment Providers;

• Suppliers;

• technology companies;

• cloud providers;

• analytics providers;

• communications providers;

• logistics companies; and

• other service providers

located in different jurisdictions.

46. INTERNATIONAL TRANSFERS

As a result of Vivera's international operations and use of third-party service providers, personal data may be:

• processed;

• accessed;

• stored; or

• transferred

outside the country in which the Customer resides, including outside Thailand.

The data protection laws of another jurisdiction may differ from those of the Customer's jurisdiction.

Where applicable law requires specific protections for international transfers, Vivera will take appropriate measures as required by applicable law.

PART XV — DATA RETENTION

47. GENERAL RETENTION PRINCIPLE

Vivera retains personal data for as long as reasonably necessary for:

• the purpose for which it was collected;

• another compatible lawful purpose;

• legal or regulatory obligations;

• accounting or tax obligations;

• fraud prevention;

• security;

• dispute management;

• chargeback management;

• enforcement of agreements; or

• establishment, exercise, or defence of legal claims.

Different types of information may have different retention periods.

48. FACTORS AFFECTING RETENTION

When determining an appropriate retention period, Vivera may consider:

• whether the Account remains active;

• whether an Order remains ongoing;

• whether a transaction is complete;

• applicable return or warranty periods;

• customer-support requirements;

• payment-dispute periods;

• chargeback risk;

• fraud-prevention needs;

• security requirements;

• accounting requirements;

• tax requirements;

• applicable legal obligations;

• applicable limitation periods; and

• whether information is needed to establish, exercise, or defend legal claims.

49. DELETION OR ANONYMISATION

When personal data is no longer reasonably necessary and Vivera has no lawful reason to continue retaining it, Vivera will take appropriate steps in accordance with applicable law and internal procedures.

Depending on the circumstances, this may include:

• deletion;

• destruction;

• anonymisation; or

• another appropriate method of disposal.

Vivera may maintain an internal data-retention schedule and review retention periods as its operations develop.

PART XVI — DATA SECURITY

50. SECURITY MEASURES

Vivera takes reasonable administrative, organizational, and technical measures designed to protect personal data against risks including:

• unauthorized access;

• unauthorized disclosure;

• loss;

• misuse;

• alteration;

• destruction; and

• other unauthorized processing.

Measures may include, where appropriate:

• access controls;

• authentication;

• restricted access;

• secure cloud infrastructure;

• monitoring;

• backups;

• security procedures; and

• other reasonable safeguards.

51. ACCESS TO PERSONAL DATA

Access to personal data should be limited to Vivera personnel, service providers, and other parties who reasonably require access for legitimate purposes.

Personnel or service providers accessing personal data are expected to handle the information appropriately and in accordance with applicable requirements.

52. NO SYSTEM IS COMPLETELY SECURE

Although Vivera takes reasonable security measures, no website, cloud system, communication method, transmission method, or electronic storage system can be guaranteed to be completely secure.

Customers are also responsible for protecting their Account credentials and devices.

PART XVII — CUSTOMER PRIVACY RIGHTS

53. PRIVACY RIGHTS

Depending on applicable law and the circumstances, Customers may have rights relating to their personal data.

These may include the right to:

• request access to personal data;

• request a copy of personal data;

• request correction of inaccurate or incomplete personal data;

• request deletion, destruction, or anonymisation where legally applicable;

• request restriction of certain processing where applicable;

• object to certain processing;

• object to direct marketing;

• withdraw consent where processing is based on consent;

• request data portability where applicable; and

• submit a complaint to an applicable data protection authority.

The availability and scope of these rights may depend on applicable law and the circumstances of the processing.

54. EXCEPTIONS TO PRIVACY REQUESTS

A privacy request does not necessarily require Vivera to immediately delete or stop processing all information relating to a Customer.

Vivera may continue processing or retaining information where required or permitted for purposes including:

• legal obligations;

• tax and accounting requirements;

• outstanding Orders;

• ongoing disputes;

• chargebacks;

• fraud investigations;

• security;

• establishment, exercise, or defence of legal claims; or

• other lawful purposes.

55. ACCOUNT DELETION

Vivera does not currently provide a self-service Account-deletion function.

Customers may nevertheless contact Vivera through its official support channels regarding privacy requests relating to their Account or personal data.

Where a valid deletion request applies and no lawful reason requires continued retention, Vivera will take appropriate action in accordance with applicable law.

Closing or deleting an Account does not necessarily result in immediate deletion of all transaction or legally required records.

56. VERIFYING PRIVACY REQUESTS

To protect personal data from unauthorized access or deletion, Vivera may need to verify the identity of a person submitting certain privacy requests.

Vivera may request information reasonably necessary to confirm that the person making the request is the relevant Customer or is otherwise legally authorized to make the request.

Verification requirements will depend on the nature and sensitivity of the request.

PART XVIII — CHILDREN AND LEGAL CAPACITY

57. AGE AND LEGAL CAPACITY

Vivera's Services are intended for persons who have the legal age and capacity required to use the applicable Services and enter into transactions under the laws applicable to them.

Legal age and capacity requirements may vary between jurisdictions.

Where a person is not legally permitted to independently provide required consent or enter into the relevant transaction, authorization or involvement of a parent, legal guardian, or other legally authorized person may be required in accordance with applicable law.

Vivera may restrict use of certain Services where necessary legal capacity or authorization cannot reasonably be established.

PART XIX — THIRD-PARTY SERVICES

58. THIRD-PARTY WEBSITES AND SERVICES

Vivera may link to or interact with independent third-party services including:

• payment providers;

• games;

• publishers;

• digital platforms;

• social media;

• logistics providers;

• communication services; and

• other external websites or services.

Vivera does not control the independent privacy practices of these third parties.

Customers should review the applicable privacy policies of third parties before providing personal data directly to them.

PART XX — BUSINESS AND CORPORATE CHANGES

59. MERGERS, ACQUISITIONS AND REORGANISATIONS

If Vivera is involved in a:

• merger;

• acquisition;

• restructuring;

• financing;

• corporate reorganisation;

• transfer of business;

• sale of assets; or

• similar transaction,

personal data may be disclosed or transferred where reasonably necessary in connection with the transaction and permitted by applicable law.

Any handling of personal data in connection with such a transaction will remain subject to applicable legal requirements.

PART XXI — CHANGES TO THIS PRIVACY POLICY

60. UPDATES TO THE PRIVACY POLICY

Vivera may update this Privacy Policy from time to time.

Changes may be made because of:

• changes to our Services;

• changes to Products;

• new technology;

• new Payment Providers;

• new Suppliers;

• new service providers;

• changes in data processing;

• security developments;

• operational changes;

• regulatory developments; or

• legal requirements.

The latest Privacy Policy will be made available through Vivera's Services.

The “Last Updated” date at the beginning of this Privacy Policy identifies when the Privacy Policy was most recently revised.

61. MATERIAL PRIVACY CHANGES

Where required by applicable law, Vivera may provide additional notice where a change materially affects how personal data is processed.

Where a particular new processing activity legally requires consent, Vivera may request appropriate consent before conducting that processing.

PART XXII — CONTACT AND PRIVACY REQUESTS

62. CONTACTING VIVERA

Customers who have questions or requests concerning:

• this Privacy Policy;

• personal data;

• privacy rights;

• Account information;

• correction requests;

• deletion requests;

• marketing preferences;

• privacy complaints; or

• other privacy matters

may contact Vivera through the official Contact Us channels available through Vivera's website and store.

Official support channels may include:

• Vivera's Contact Us form;

• Vivera's official support email;

• Vivera's official LINE account; and

• Vivera's official WhatsApp support channel.

Customers should use only official Vivera channels when submitting personal information or privacy requests.

63. DATA CONTROLLER CONTACT INFORMATION

Data Controller:

Vivera Solutions Co., Ltd.

Registered Address:

18/9, Floor 2, Soi Udom Suk 31,

Bang Chak, Phra Khanong,

Bangkok 10260, Thailand

Privacy enquiries and personal-data requests may be submitted through Vivera's official Contact Us channels.

64. PRIVACY COMPLAINTS

If you have concerns about how Vivera handles your personal data, you are encouraged to contact Vivera so that we can investigate and respond to the concern.

Depending on applicable law, you may also have the right to submit a complaint to the competent data protection authority.

Nothing in this Privacy Policy is intended to restrict a privacy or data-protection right that cannot lawfully be excluded.