Privacy Policy for Customer

We will collect your personal data that receive directly from you as following:

• your account registration
• telephone
• email address

Personal data such as name, surname, age, date of birth, nationality, identification card, passport, etc.

Contact information such as address, telephone number, e-mail address, etc.

Account details such as username, password, transactions history, etc.

Proof of identity such as copy of identification card, copy of passport, etc.

Transaction and Financial information such as purchase history, credit card details, bank account, etc.

Technical data such as IP address, Cookie ID, Activity Log, etc.

Other such as photo, video, and other information that is considered personal data under the Personal Data Protection Laws.

If you are under the age of 20 or having legal restrictions, we may collect use or disclose your personal data. We require your parents or guardian to be aware and provide consent to us or allowed by applicable laws. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

We store your personal data as hard copy and soft copy.

We store your personal data by using the following systems:

• Third-party server service providers in Thailand
• Third-party server service providers outside of Thailand

We use the collected data for various purposes:

• To create and manage accounts
• To provide products or services
• To improve products, services, or user experiences
• To share and manage information within organization
• To conduct marketing activities and promotions
• To provide after-sales services
• To gather user’s feedback
• To process payments of products or services
• To comply with our Terms and Conditions
• To comply with laws, rules, and regulatory authorities

We may disclose your personal data to the following parties in certain circumstances:

Organization

We may disclose your personal data within our organization to provide and develop our products or services. We may combine information internally across the different products or services covered by this Privacy Policy to help us be more relevant and useful to you and others.

Service Providers

We may use service providers to help us provide our services such as payments, marketing and development of products or services. Please note that service providers have their own privacy policy.

Business Partners

In relation with our business partners, we may disclose certain personal data to them in order to coordinate and provide our products or services to you and provide necessary information about the availability of our products or services.

Law Enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by government authority such as courts, government authorities.

We may disclose or transfer your personal data to third parties, organizations or servers located in foreign countries. We will take steps and measures to ensure that your personal data is securely transferred, and the receiving parties have an appropriate level of personal data protection standard or as allowed by laws.

We will retain your personal data for as long as necessary during the period you are a customer or under relationship with us, or for as long as necessary in connection with the purposes set out in this Privacy Policy, unless law requires or permits a longer retention period. We will erase, destroy or anonymize your personal data when it is no longer necessary or when the period lapses.

Subject to the Personal Data Protection Laws thereof, you may exercise any of these rights in the following:

Withdrawal of consent: If you have given consent to us to collect, use or disclose your personal data whether before or after the effective date of the Personal Data Protection Laws, you have the right to withdraw such consent at any time throughout the period your personal data available to us, unless it is restricted by laws or you are still under beneficial contract.

Data access: You have the right to access your personal data that is under our responsibility; to request us to make a copy of such data for you; and to request us to reveal as to how we obtain your personal data.

Data portability: You have the right to obtain your personal data if we organize such personal data in automatic machine-readable or usable format and can be processed or disclosed by automatic means; to request us to send or transfer the personal data in such format directly to other data controllers if doable by automatic means; and to request to obtain the personal data in such format sent or transferred by us directly to other data controller unless not technically feasible.

Objection: You have the right to object to collection, use or disclosure of your personal data at any time if such doing is conducted for legitimate interests of us, corporation or individual which is within your reasonable expectation; or for carrying out public tasks.

Data erasure or destruction: You have the right to request us to erase, destroy or anonymize your personal data if you believe that the collection, use or disclosure of your personal data is against relevant laws; or retention of the data by us is no longer necessary in connection with related purposes under this Privacy Policy; or when you request to withdraw your consent or to object to the processing as earlier described.

Suspension: You have the right to request us to suspend processing your personal data during the period where we examine your rectification or objection request; or when it is no longer necessary and we must erase or destroy your personal data pursuant to relevant laws but you instead request us to suspend the processing.

Rectification: You have the right to rectify your personal data to be updated, complete and not misleading.

Complaint lodging: You have the right to complain to competent authorities pursuant to relevant laws if you believe that the collection, use or disclosure of your personal data is violating or not in compliance with relevant laws.

You can exercise these rights as the Data Subject by contacting our Data Protection Officer as mentioned below. We will notify the result of your request within 30 days upon receipt of such request. If we deny the request, we will inform you of the reason via SMS, email address, telephone, registered mail (if applicable).

To enrich and perfect your experience, we use cookies or similar technologies to display personalized content, appropriate advertising and store your preferences on your computer. We use cookies to identify and track visitors, their usage of our website and their website access preferences. If you do not wish to have cookies placed on your computer you should set their browsers to refuse cookies before using our website.

We endeavor to protect your personal data by establishing security measures in accordance with the principles of confidentiality, integrity, and availability to prevent loss, unauthorized or unlawful access, destruction, use, alteration, or disclosure including administrative safeguard, technical safeguard, physical safeguard and access controls.

We will notify the Office of the Personal Data Protection Committee without delay and, where feasible, within 72 hours after having become aware of it, unless such personal data breach is unlikely to result in a risk to the rights and freedoms of you. If the personal data breach is likely to result in a high risk to the rights and freedoms of you, we will also notify the personal data breach and the remedial measures to you without delay through our website, SMS, email address, telephone or registered mail (if applicable).

We may change this Privacy Policy from time to time. Any changes of this Privacy Policy, we encourage you to frequently check on our website.

This Privacy Policy was last updated and effective on 27th July 2026

The purpose of this Privacy Policy is to offer products or services and use of our website. Any websites from other domains found on our site is subject to their privacy policy which is not related to us.

If you have any questions about this Privacy Policy or would like to exercise your rights, you can contact us by using the following details:

Data Controller

HB ACCOUNTING CO., LTD. 58-60 Rama III Soi 29, Bang Phongphang, Yan Nawa, Bangkok, 10120 hbgtech@hbg-th.com https://hbgfinance.com 0944725555

Data Protection Officer

Kantinan Boonchalee 58-60 Rama III Soi 29, Bang Phongphang, Yan Nawa, Bangkok, 10120 omu.kantinan@hbg-th.com 0957079365

This appendix supplements the policy above specifically for the WOOP learning platform, on the web and in our mobile apps. Where this appendix conflicts with the main policy, the main policy prevails.

In addition to the categories listed above, using the platform generates the following data:

• Learning data: courses you enrol in or are assigned, video and document progress, quiz answers and scores, learning paths, assessed competency levels, and certificates issued to you with their public verification code
• Organisation membership data: the organisation, company, department, job title, your manager, and your role there
• Game data: XP, level, points, learning streaks, achievements, and avatar items
• Community activity: posts, comments, and reactions you create
• Live classes: audio and video from your camera and microphone are relayed to other participants only while you are in a room and have turned them on, along with in-room chat messages and a recording of the session where the class is recorded
• Messages you send to the AI assistant, so it can answer them
• Order data: your orders, the amount in baht or coins, payment status, the transaction reference from our payment provider, and for shipped goods the recipient name, phone number, and delivery address

What the WOOP app does not collect: we do not collect your GPS location, do not access your contacts, calendar, photo library, or installed-app list, and we do not sell your personal data to anyone.

The mobile app requests only what a feature actually needs, at the moment you use it:

• Camera and microphone — used only in live classes, so you can speak or turn your camera on when the instructor allows it. You can decline and still attend view-only.
• Notifications — used for deadlines, assigned courses, and classes about to start. You can turn them off in Settings.
• Files and photos — used only when you pick a file to upload. We do not scan your photo library.

You can revoke any of these at any time in your device’s system settings, and the rest of the app keeps working.

Under “Service Providers” above, the providers we use for this platform are:

• cloud infrastructure and object storage providers — hosting the database, course video, and certificate files
• Omise — payment processing via PromptPay; payment details go to the provider directly and we do not store card numbers or bank account details on our systems
• LiveKit — relaying audio and video for live classes
• Anthropic (Claude API) — processing the messages you send to the AI assistant in order to answer them; this data is not used to train models
• email and push notification providers, including Apple’s and Google’s push services on mobile
• Apple App Store and Google Play — app distribution and aggregated crash reporting

Your account is yours, not your employer’s. When you join an organisation by invitation, that organisation’s administrators, HR, and your manager there see only the learning that happens inside it — the courses it assigns, your progress, quiz scores, and certificates it issued.

One organisation cannot see your learning at another organisation or your personal learning, unless you choose to share a specific certificate. Your profile is shown to partner recruiters only when you switch on “open to work” yourself.

If you leave or are removed from an organisation, your account and personal learning history remain. An organisation cannot delete your account.

You may request deletion of your account and personal data at any time, under the data erasure right above, by emailing omu.kantinan@hbg-th.com from the address on your account with the subject “Delete my WOOP account”. Full instructions are on the “Delete my account” page of our website.

We will verify your identity and notify you of the result within 30 days of receiving the request.

Leaving one organisation is not the same as deleting your account — to leave an organisation, contact that organisation’s administrator.