Privacy Policy

This Privacy Policy explains how Krungthai-AXA Life Insurance Public Company Limited (“we,” “us,” or “our”), developer and operator of TOUCH by KTAXA, collects, stores, uses, and shares (“processes”) your personal data when you interact with our application our website at https://www.zennite.co/axa-privacy-policy.html , or any other website of ours that links to this Privacy Policy (collectively, our “Services”).

Important Note:

• This Privacy Policy is linked on our Google Play Store listing and is accessible within the TOUCH by KTAXA app.
• It is publicly available without geolocation restrictions and requires no special plug-ins or software for viewing.
• Once posted, this document is non-editable to maintain its integrity.

If you have questions or concerns about this Policy or your privacy rights, you can contact us at:

Email: dpo@krungthai-axa.co.th

Mail: Krungthai-AXA Life Insurance Public Company Limited
  9, G Tower Grand Rama 9 Floor 1,22-27, Rama 9 Road,
  Huai Khwang, Huai Khwang, Bangkok 10310, Thailand

If you do not agree with our policies and practices, please discontinue use of our Services.

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. WHAT ARE YOUR PRIVACY RIGHTS?
6. CONTROLS FOR DO-NOT-TRACK FEATURES
7. UPDATES TO THIS PRIVACY POLICY
8. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
9. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

We collect personal information that you voluntarily provide to us, as well as information collected automatically when you use the Services.

1.1 Personal Information You Provide

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames and passwords
• Contact preferences
• Contact or authentication data

All personal information that you provide must be true, complete, and accurate, and you must notify us of any changes.

1.2 Health and Fitness Data (Health Connect)

TOUCH by KTAXA accesses, collects, and processes limited health and fitness data through Health Connect to provide activity-tracking and wellness features. Health data is sensitive personal information and is processed only as described below.

Health Data We Access and Collect:

• Step count data: We read your daily step count from Health Connect to track and display your physical activity and your progress in wellness activities, challenges, or events available through the app.
• We do not access or collect other Health Connect data types, such as heart rate, sleep, weight, blood pressure, medical records, or reproductive health data.

How We Access and Collect Health Data:

• We access step count data from Health Connect only after you grant explicit permission through the Android permission screen.
• Health Connect may aggregate step count data from fitness apps and connected devices on your Android device. TOUCH by KTAXA reads only the data type you authorize and only as needed to provide the features described in this Policy.
• Providing Health Connect access is optional. You can deny or revoke permission at any time. Features that rely on step count data may not function after access is denied or revoked.

How We Use Health Data:

• To display your step count and activity progress within TOUCH by KTAXA.
• To enable and manage your participation in step-based wellness activities, challenges, rewards, or events.
• To calculate activity achievements and milestones and provide relevant activity insights.
• To maintain, secure, troubleshoot, and improve the health-related features you choose to use.

Restrictions on Use:

• We do not sell, rent, or use Health Connect data for advertising, targeted advertising, or marketing.
• We do not use your step count data to determine insurance eligibility, premiums, underwriting, or claim decisions.
• We do not use Health Connect data for any purpose that is unrelated to the health and fitness features described in this Policy.

Legal Basis and Your Control:

• We process Health Connect data based on your explicit consent when you grant the requested permission.
• You can revoke access at any time in TOUCH by KTAXA or in your Android device's Health Connect permission settings.
• You can request access to or deletion of health data that we store by contacting dpo@krungthai-axa.co.th.

1.3 Information Collected Automatically

We automatically collect certain technical information when you use the Services, which may include:

• Log and Usage Data (IP address, browser type, timestamps, pages viewed, etc.)
• Device Data (device model, operating system, unique device identifiers)
• Location Data (approximate or precise geolocation if you grant permission)

This data is used primarily for security, analytics, and to help improve our Services.

We process your personal information for several reasons, depending on how you interact with our Services, including to:

• Facilitate account creation and authentication.
• Provide services you request, including supporting and improving our app features.
• Provide optional health and fitness features, including accessing and displaying your Health Connect step count, tracking activity progress, and managing participation in step-based wellness activities, challenges, rewards, or events.
• Communicate with you, including sending updates, responding to inquiries, and providing information about new features.
• Enhance security and detect fraud, including detecting and preventing unauthorized access or other illegal activities.
• Comply with legal obligations, such as responding to lawful requests from public authorities.

We only process your information if we have a valid legal reason, such as your consent, contractual necessity, compliance with laws, or legitimate interests.

We may share your information under specific circumstances, such as:

• Business Transfers: In connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Legal Requirements: If we are legally required to disclose your information in response to lawful requests from public authorities, such as courts or government agencies.

Health Data Sharing:

• We do not sell, rent, or share Health Connect data with advertising platforms, data brokers, or other third parties for advertising or marketing.
• We may disclose step count data only to authorized service providers that process data on our behalf when necessary to host, secure, maintain, or operate the health and fitness features. These providers must follow our instructions, maintain confidentiality, and apply appropriate security safeguards.
• We may disclose health data when required by applicable law or a valid legal process. We may also use or share aggregated or anonymized statistics that cannot reasonably identify you.

We do not sell your personal information to third parties. When sharing is necessary, we ensure that appropriate data protection and confidentiality measures are in place.

We keep your personal information only for as long as needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law (such as for tax, accounting, or legal obligations).

Health Connect data is retained only for as long as necessary to provide the health and fitness features you use, comply with applicable legal obligations, resolve disputes, and enforce our agreements. When it is no longer needed, or when we approve a valid deletion request, we delete or anonymize it unless retention is required by law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If that is not possible (for instance, because your information is stored in backup archives), we will securely store your information and isolate it from any further processing until deletion is possible.

Depending on your location and applicable law, you may have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data when no longer necessary for the purposes collected.
• Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw it at any time.
• Revoke Health Connect Access: Remove TOUCH by KTAXA's Health Connect permissions at any time through the app or your Android device's Health Connect permission settings. Revoking access does not delete data already stored by us; you may request its deletion by contacting us.

To exercise any of your rights, or if you have questions or comments about your privacy rights, please email us at dpo@krungthai-axa.co.th.

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature to signal that you prefer not to have your online activities tracked. A uniform DNT standard is not yet adopted, so we currently do not respond to DNT signals. If such a standard is adopted in the future, we will update this Privacy Policy accordingly.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Revised” date and will become effective as soon as it is accessible. We encourage you to review this notice frequently to stay informed about how we are protecting your information.

If we make material changes, we may notify you either by prominently posting a notice or by sending you a direct notification (e.g., via email or in-app notification).

If you have questions or comments about this Privacy Policy, you may contact us by:

Email: dpo@krungthai-axa.co.th

Mail: Krungthai-AXA Life Insurance Public Company Limited
  9, G Tower Grand Rama 9 Floor 1,22-27, Rama 9 Road,
  Huai Khwang, Huai Khwang, Bangkok 10310, Thailand

Based on applicable laws, you may have the right to request access to, update, or delete the personal data we collect about you. To request to review, update, or delete your personal information, please contact us at dpo@krungthai-axa.co.th

By using TOUCH by KTAXA and associated Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our policies and practices, please discontinue use of our Services.

Thank you for reading our Privacy Policy. We are committed to protecting and respecting your personal data. If you have any questions about this Policy, please reach out to us at dpo@krungthai-axa.co.th