PRIVACY POLICY
Zmootz Vive Co., Ltd. | Wellkub Platform
Document No.: WK-LEGAL-001 Version 2.0 Effective Date: As announced by Wellkub on the Platform
SECTION 1 — INTRODUCTION AND SCOPE
Zmootz Vive Co., Ltd. (“Company” or “Wellkub”) respects and is committed to protecting the personal data of users, members, customers, service users, service providers, partners, contact persons, and other individuals interacting with the Wellkub platform.
This Privacy Policy (“Policy”) explains how Wellkub collects, uses, discloses, transfers, stores, and protects your personal data, as well as your rights as a data subject under the Personal Data Protection Act B.E. 2562 (2019) of Thailand (“PDPA”) and other applicable laws.
Wellkub operates as a digital marketplace and intermediary platform for the discovery, comparison, contact, booking, payment, and transaction coordination of health, wellness, body recovery, rehabilitation, and related services offered by participating service providers.
This Policy applies to the use of Wellkub’s website, systems, digital channels, LINE Official Account, customer support channels, booking services, payment transactions, requests, complaints, membership programmes, and other interactions with Wellkub.
Your use of Wellkub’s services does not mean that you automatically consent to every type of personal data processing. Wellkub will process your personal data based on the appropriate lawful basis, which may include contract performance, legal obligation, legitimate interest, prevention or suppression of danger to life, body, or health, or your consent where consent is required by law.
SECTION 2 — PERSONAL DATA CONTROLLER
Company Name: Zmootz Vive Co., Ltd. Company Registration No.: 0115564005545 Address: 343/5 Khlong Lam Chiak Road, Nuan Chan Subdistrict, Bueng Kum District, Bangkok 10230, Thailand Brand / Platform: Wellkub Website: [www.wellkub.com](http://www.wellkub.com) Personal Data Contact Email: [support_team@wellkub.com](mailto:support_team@wellkub.com) LINE Official Account: @wellkub
In general, Wellkub acts as a personal data controller for personal data collected, used, or disclosed for the operation of the Platform, user account administration, bookings, payments, coordination, marketing, system analytics, fraud prevention, and legal compliance.
In some cases, service providers such as hospitals, clinics, wellness establishments, wellness centres, or other operators may act as separate personal data controllers for personal data they collect, use, or disclose for the actual provision of services, consultation, assessment, treatment, rehabilitation, or healthcare-related services.
SECTION 3 — DEFINITIONS
“Personal Data” means any information relating to a natural person which enables the identification of such person, whether directly or indirectly, but does not include information of deceased persons specifically.
“Sensitive Personal Data” means personal data under Section 26 of the PDPA, including health data, medical history, biometric data, religion, race, political opinions, criminal records, trade union information, sexual behaviour, or other data prescribed by law.
“Health Data” means information relating to physical or mental health, symptoms, medical conditions, treatment history, test results, health limitations, information relating to health, wellness, recovery, or rehabilitation services, or other information that may reflect a person’s health condition.
“Data Subject” means the natural person to whom the personal data relates.
“User” means a person who visits, uses, registers, books, pays, contacts, or conducts transactions through the Wellkub platform.
“Service Provider” means a hospital, clinic, health establishment, wellness centre, wellness resort, or other operator offering or providing products or services through or in connection with Wellkub.
“Processing” means the collection, use, disclosure, storage, transfer, deletion, destruction, or any operation performed on personal data.
“Cookies” means small files or technologies used to store or access information on a user’s device in order to enable website functionality, remember settings, analyse usage, or support marketing, depending on the type of cookies used.
SECTION 4 — PERSONAL DATA WELLKUB MAY COLLECT
4.1 Personal Data You Provide Directly
Wellkub may collect personal data that you provide directly, including:
(1) Identity information, such as name, surname, date of birth, age, gender, nationality, or identity verification information where necessary;
(2) Contact information, such as address, telephone number, email address, LINE ID, or other contact details;
(3) Account information, such as username, password in encrypted or protected form, login history, and account settings;
(4) Booking information, such as service type, package, selected Service Provider, appointment date and time, booking status, rescheduling history, cancellation history, and service usage history;
(5) Payment information, such as transaction status, payment amount, payment method, transaction reference number, card type, and partial card number as provided by the payment service provider. Wellkub does not store full card numbers or card security codes unless handled in accordance with applicable payment security standards and laws;
(6) Contact and communication information, such as messages sent through LINE OA, email, contact forms, chat support, telephone, complaints, refund requests, data subject requests, and documents submitted to Wellkub;
(7) Membership and benefits information, such as membership status, points, accumulated spending, benefits usage history, or reward redemption history, only when Wellkub has officially launched the relevant system;
(8) Referral, affiliate, or partner-related information, such as referral codes, referral history, related reward or commission records, or information necessary to verify and prevent misuse of the system.
4.2 Health Data and Sensitive Personal Data
Wellkub may collect or process your health data or sensitive personal data only to the extent necessary and appropriate, including:
(1) Symptoms or health concerns you provide for the purpose of selecting a suitable service;
(2) Medical conditions, treatment history, health limitations, or precautions relevant to the booked service;
(3) Medical documents, medical certificates, or evidence submitted for rescheduling, cancellation, refund, or emergency review;
(4) Other sensitive data that you voluntarily provide to Wellkub or a Service Provider.
Wellkub will process health data or sensitive personal data only with your explicit consent or where an exemption under applicable law applies, such as where necessary to prevent or suppress danger to a person’s life, body, or health, or where otherwise expressly permitted by law.
4.3 Data Collected Automatically
When you use the Wellkub platform, the system may automatically collect certain information, including:
(1) IP address, browser type, operating system, device identifier, and device type;
(2) Pages visited, click sequence, session duration, session data, and website usage behaviour;
(3) Cookies, pixels, web beacons, SDKs, or similar tracking technologies;
(4) Approximate location derived from IP address, or more precise location data only where permitted through your device or browser settings;
(5) Data from LINE Login or third-party login systems, such as LINE User ID, display name, or profile picture, within the scope permitted by you through the relevant third-party provider.
4.4 Data from Third Parties
Wellkub may receive personal data from third parties, including:
(1) Payment service providers, banks, or payment gateway providers;
(2) Analytics and marketing service providers, such as Google Analytics, Meta Pixel, or advertising and analytics providers;
(3) Service Providers with whom you make bookings through the Platform;
(4) IT, cloud, CRM, messaging, email, or customer support service providers;
(5) Persons who refer you to Wellkub or provide information on your behalf, provided that there is an appropriate lawful basis or authority to provide such information to Wellkub.
SECTION 5 — LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Wellkub will process your personal data based on the lawful basis appropriate to the relevant purpose, which may include:
(1) Contract performance or steps prior to entering into a contract, such as account registration, booking, booking confirmation, payment, coordination with Service Providers, and booking administration;
(2) Consent, such as for processing health data or sensitive personal data, non-essential analytics or marketing cookies, certain direct marketing activities, or disclosure of certain data to Service Providers where consent is required by law;
(3) Legitimate interests, such as platform security, fraud prevention, service analysis and improvement, complaint management, transaction review, and protection of the rights of Wellkub, users, Service Providers, or other persons, provided that your rights and freedoms are duly considered;
(4) Legal obligation, such as compliance with tax, accounting, consumer protection, electronic transaction, personal data protection, or regulatory requirements, or orders of competent authorities;
(5) Prevention or suppression of danger to life, body, or health, such as in emergency situations where information may need to be shared with relevant Service Providers or personnel within the scope permitted by law;
(6) Any other lawful basis permitted by applicable law.
SECTION 6 — PURPOSES OF COLLECTION, USE, AND DISCLOSURE
Wellkub may collect, use, or disclose your personal data for the following purposes:
6.1 Platform, Booking, and Coordination Services
(1) Creating and administering user accounts;
(2) Receiving, verifying, confirming, and managing bookings;
(3) Coordinating between you and Service Providers;
(4) Sending Payment Confirmations, Order Confirmations, or Booking Confirmations;
(5) Sending appointment reminders, booking status updates, rescheduling, cancellation, or service-related notices;
(6) Managing service use, Service Completed confirmation, complaints, and after-service communications.
6.2 Payment, Refund, and Transaction Management
(1) Processing payment information through payment service providers;
(2) Verifying transaction status and preventing fraud;
(3) Preparing payment confirmations or transaction-related documents;
(4) Processing or coordinating refunds, cancellations, or transaction disputes;
(5) Preparing information necessary for calculating fees, commissions, or settlements between Wellkub and Service Providers.
6.3 Customer Support and Complaint Handling
(1) Responding to enquiries, providing support, and tracking requests;
(2) Reviewing complaints, refund requests, rescheduling requests, or service-related issues;
(3) Maintaining contact records to improve service quality.
6.4 Membership, Points, and Benefits Programmes
When Wellkub officially launches a membership, points, accumulated spending, or benefits programme, Wellkub may process personal data to:
(1) Administer membership tiers, points, accumulated spending, and benefits;
(2) Notify users of points status, points expiry, or benefits;
(3) Verify benefit usage and prevent misuse.
Before the relevant system is officially launched, data in this section will not automatically create any entitlement to points, accumulated spending, or membership tiers.
6.5 Marketing, Public Relations, and Behavioural Analytics
Wellkub may process personal data to:
(1) Send news, promotions, content, or offers relating to Wellkub services where there is an appropriate lawful basis or consent as required by law;
(2) Analyse campaign performance, website visits, and service usage;
(3) Conduct remarketing or retargeting through third-party platforms only where consent has been obtained for relevant cookies or marketing technologies.
You may opt out of direct marketing or withdraw consent through the channels designated by Wellkub.
6.6 Security, Fraud Prevention, and Enforcement of Terms
Wellkub may process personal data to maintain platform security, monitor access, prevent fraud, misuse of accounts, breach of terms, and protect the rights or property of Wellkub, users, Service Providers, or other persons.
6.7 Legal Compliance
Wellkub may process personal data to comply with laws, regulations, court orders, government orders, or legal obligations, including tax, accounting, consumer protection, personal data protection, and dispute management obligations.
SECTION 7 — HEALTH DATA AND SENSITIVE PERSONAL DATA
Wellkub will collect, use, or disclose health data or sensitive personal data only to the extent necessary for the stated purposes and based on an appropriate lawful basis.
Where explicit consent is required, Wellkub will request such consent separately and will inform you of the purposes, data categories, recipients, and potential consequences of not providing the relevant data, where appropriate.
Wellkub may disclose health data to the Service Provider selected by you only to the extent necessary to assess service suitability, prepare for the service, reduce health risks, or respond to your request.
Wellkub will not use health data or sensitive personal data for targeted marketing unless permitted by law and your explicit consent has been obtained where required.
SECTION 8 — COOKIES AND TRACKING TECHNOLOGIES
Wellkub may use cookies and similar technologies to enable the website to function properly, remember your settings, analyse usage, and support digital marketing depending on the type of cookies used.
The types of cookies that may be used include:
(1) Strictly Necessary Cookies: Cookies necessary for website operation, such as login, security, and session maintenance. These cannot be disabled through the website’s consent banner;
(2) Functional Cookies: Cookies that remember settings such as language, region, or user preferences;
(3) Analytics Cookies: Cookies used to analyse website usage, such as Google Analytics, used in accordance with your consent where required by law;
(4) Marketing Cookies: Cookies or pixels used for advertising, remarketing, retargeting, or advertising measurement, such as Meta Pixel, used in accordance with your consent where required by law.
You may manage cookie consent through the Cookie Consent Banner or privacy settings on the website and may also adjust your browser settings.
Further details may be provided in Wellkub’s separate Cookie Policy.
SECTION 9 — DISCLOSURE OF PERSONAL DATA
Wellkub may disclose your personal data to the following persons or organisations to the extent necessary and consistent with the stated purposes:
(1) Service Providers selected by you, such as hospitals, clinics, health establishments, wellness centres, or related operators;
(2) Payment service providers, banks, card issuers, or payment system providers;
(3) IT, cloud, hosting, CRM, email, messaging, analytics, security, or service support providers;
(4) Marketing and analytics service providers, such as Google, Meta, or other advertising providers, where an appropriate lawful basis or consent exists;
(5) Legal, accounting, tax, audit, or other professional advisers;
(6) Government authorities, courts, officials, or regulators with lawful authority;
(7) Business transferees, joint venture partners, or contractual parties involved in a merger, business transfer, restructuring, or corporate transaction, subject to appropriate data protection measures.
Wellkub will not sell your personal data to third parties.
SECTION 10 — INTERNATIONAL TRANSFER OF PERSONAL DATA
Wellkub may transfer your personal data to another country, for example when using cloud, analytics, advertising, messaging, email, payment, or system service providers with servers or affiliates outside Thailand.
International transfers of personal data will be carried out in accordance with the PDPA and applicable regulations, including where the destination country has adequate personal data protection standards or where appropriate safeguards are implemented, such as contractual safeguards, organisational and technical measures, or other mechanisms permitted by law.
Where consent is required by law for a particular international transfer, Wellkub will obtain such consent in accordance with applicable law.
SECTION 11 — DATA RETENTION
Wellkub will retain your personal data only for as long as necessary for the stated purposes, applicable lawful bases, legal compliance, claims, dispute prevention, and transaction verification.
In general, Wellkub may retain personal data as follows:
(1) Account information: for as long as the account remains active and thereafter for a period necessary for verification, dispute prevention, and legal compliance;
(2) Booking, transaction, and payment information: for the period necessary for accounting, tax, transaction review, disputes, and applicable legal obligations;
(3) Health data or sensitive personal data: only as long as necessary for the consented purpose or applicable lawful basis, with access limited as appropriate;
(4) Marketing data: until you withdraw consent, unsubscribe, or the data is no longer necessary for the relevant purpose;
(5) Cookies and website usage data: for the period stated in the Cookie Policy or applicable cookie settings;
(6) Complaint, data subject request, and contact records: for the period necessary to manage requests, complaints, disputes, and legal compliance.
After the retention period ends or the data is no longer necessary, Wellkub will delete, destroy, or anonymise the data using appropriate measures.
SECTION 12 — SECURITY MEASURES
Wellkub will implement personal data security measures appropriate to the nature of the data, risk, and processing context, which may include:
(1) Restricting data access based on role and necessity;
(2) Passwords, authentication, or access control measures;
(3) Encryption or other protective measures for data transmission where appropriate;
(4) Logging and monitoring system access where necessary;
(5) Internal measures regarding confidentiality and personal data use;
(6) Data protection obligations imposed on external service providers or data processors where appropriate;
(7) Periodic review of security measures based on risk and appropriateness.
Where Wellkub refers to specific standards such as ISO/IEC 27001, penetration testing, or other standards, Wellkub will do so only where such measures have actually been implemented or are supported by verifiable documentation.
SECTION 13 — PERSONAL DATA BREACH
If a personal data breach occurs, Wellkub will assess the nature of the incident, affected data, risk to the rights and freedoms of data subjects, and appropriate remedial measures.
Where the personal data breach is likely to result in a risk to the rights and freedoms of individuals, Wellkub will notify the Personal Data Protection Committee without undue delay and, where feasible, within seventy-two (72) hours after becoming aware of the incident, unless otherwise provided or permitted by law.
Where the personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, Wellkub will notify the affected data subjects without undue delay and provide appropriate remedial guidance as required by law.
SECTION 14 — DATA SUBJECT RIGHTS
Subject to the rules, conditions, and exceptions under applicable law, you may have the following rights in relation to your personal data:
(1) Right to access and obtain a copy of your personal data;
(2) Right to rectification of inaccurate, outdated, incomplete, or misleading personal data;
(3) Right to erasure, destruction, or anonymisation of personal data;
(4) Right to restriction of processing;
(5) Right to data portability where required by law;
(6) Right to object to processing in cases prescribed by law;
(7) Right to withdraw consent where Wellkub processes personal data based on consent. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal;
(8) Right to lodge a complaint with the Personal Data Protection Committee or other competent authority.
You may submit a data subject request by email at [support_team@wellkub.com](mailto:support_team@wellkub.com) or through another channel designated by Wellkub.
Wellkub will review and respond to your request within the period required by law and may request additional information to verify your identity or your relationship to the relevant data where necessary and reasonable.
SECTION 15 — WITHDRAWAL OF CONSENT AND CONSEQUENCES OF NOT PROVIDING DATA
Where Wellkub processes personal data based on consent, you may withdraw your consent at any time through a channel designated by Wellkub.
Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
However, if you do not provide data or withdraw consent for data necessary for certain services, Wellkub or the Service Provider may be unable to provide the service, coordinate a booking, process a request, verify a transaction, or manage certain matters for you. Wellkub will inform you of any material consequences where appropriate.
SECTION 16 — DIRECT MARKETING
Wellkub may send you news, promotions, content, or marketing offers only where there is an appropriate lawful basis or consent as required by law.
You may opt out of direct marketing at any time through an unsubscribe link in an email, account settings, the channel specified in the message, or by contacting Wellkub.
After you opt out of marketing, Wellkub may still send service-related communications, such as booking confirmations, appointment reminders, payment notices, refund notices, account security notices, or legally required information.
SECTION 17 — MINORS
Wellkub’s services are generally intended for persons who are at least eighteen (18) years of age.
Where Wellkub collects, uses, or discloses personal data of a minor, incompetent person, or quasi-incompetent person, Wellkub will comply with applicable legal requirements, including obtaining consent from a lawful representative, guardian, or curator where required by law.
If Wellkub becomes aware that personal data of a minor has been provided without proper authority or required consent, Wellkub may delete, restrict, or suspend processing of such data as appropriate.
SECTION 18 — THIRD-PARTY LINKS AND PLATFORMS
The Wellkub platform may contain links to third-party websites, applications, payment systems, Service Provider platforms, or services.
The processing of personal data by such third parties is governed by their own privacy policies and terms. Wellkub recommends that you read the privacy policies of such third parties before providing data or using their services.
SECTION 19 — CONTACT AND COMPLAINTS
If you have any questions, data subject requests, or complaints concerning personal data, you may contact Wellkub at:
Zmootz Vive Co., Ltd.
343/5 Khlong Lam Chiak Road Nuan Chan Subdistrict Bueng Kum District Bangkok 10230 Thailand
Personal Data Contact Email: [support_team@wellkub.com](mailto:support_team@wellkub.com) Website: [www.wellkub.com](http://www.wellkub.com) LINE Official Account: @wellkub
Wellkub will receive, review, and respond to your request within the period required by law or within a reasonable period depending on the nature and complexity of the matter.
If you believe that Wellkub has processed your personal data unlawfully, you have the right to lodge a complaint with the Personal Data Protection Committee or another competent authority under applicable law.
SECTION 20 — CHANGES TO THIS POLICY
Wellkub may amend, supplement, or update this Policy from time to time to reflect changes in law, business operations, technology, or Platform services.
Where a material change is made, Wellkub will notify you through the Platform, email, or another appropriate channel before or at the time the change becomes effective, as appropriate and as required by law.
Changes to this Policy will not affect consent where the law requires new consent to be obtained, unless Wellkub has obtained such new consent in accordance with applicable law.
SECTION 21 — LANGUAGE
This Policy may be prepared in Thai and English. In the event of any inconsistency or discrepancy between the two versions, the Thai version shall prevail to the extent permitted by applicable law and provided that this shall not exclude or restrict any data subject rights protected under applicable law.
Document No.: WK-LEGAL-001 Privacy Policy Zmootz Vive Co., Ltd. | Wellkub Version 2.0