Thai Spa”, “we”, or “our”) collects from its customers (“Customer”, “you” or “your”) in relation
to our services, including massage, spa or personal care treatments, aromatherapy, reflexology,
and our related websites (the “Services”). This Policy also describes how we use and disclose
such information, as well as your rights with respect to Sabai Thai Spa’s collection, use, and
disclosure of such information.
We understand the importance of your privacy and we treat all information we receive in a
responsible manner. By using the Services, you agree that we may collect, use, and disclose
Personal Data, Aggregate Information, and Cookies (all defined below) pursuant to this Policy.
We may change or update this Policy from time to time by posting a revised version on our
website or otherwise making the revised Policy available in our spas. Services, such as on
Sabai Thai Spa’s website. So, you should periodically verify the date of this Policy to ensure
that you are familiar with the most up-to-date version, as the most up-to-date version will govern
your use of the Services.
Information We Collect
When you use the Services, Sabai Thai Spa may collect three types of information:
(1) Personal Data: Personal Data (i.e. personal information) is any information directly or
indirectly relating to an identified or identifiable individual, such as a name, contact information,
financial information (e.g. credit card information), identification numbers, location data, online
identifiers, or one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that individual.
(2) Aggregate Information: Aggregate Information is information about your use of the
Services that typically cannot be used to identify, locate, or contact you. For example,
Aggregate Information includes information regarding the frequency of use of the Services,
quantity and type (but not content) of information collected or disclosed when using the
Services, the kinds of the Services most frequently used, and browser types used to access our
(3) Cookies, etc: Cookies, beacons, device identifiers, or similar technologies (referred to for
convenience as “Cookies”) are small pieces of data placed on your device that your web
browser or device uses to access the Services and that permit Sabai Thai Spa to track your
activity on the Services. We obtain information from Cookies when, for example, you visit Sabai
Thai Spa’s website. You may turn off cookies in your browser or device settings, but this may
limit functionality of the Services. Cookies help analyze usage and provide certain functionality.
Cookies don’t contain Personal Data and for that reason, we treat Cookies in the same manner
as we treat Aggregate Information. If Cookies do contain Personal Data, such Personal Data
will only be used or disclosed in the same manner as other Personal Data pursuant to this
Policy. Cookies cannot be used as a malicious tool.
Collecting Personal Data
Sabai Thai Spa collects Personal Data when:
(1) you book an appointment for Services;
(2) you sign up for the Services, including our “on-boarding documents” such as a
consent, waiver, etc;
(3) you use certain aspects of the Services that require the collection of Personal Data in
order for us to perform the Services;
(4) to comply with legal or regulatory requirements
(5) you voluntarily provide Personal Data through or during the Services; or
(6) you communicate with Sabai Thai Spa, regardless of the form or manner of
communication, such as in-person, e-mail or telephone.
Collecting Aggregate Information
Sabai Thai Spa collects Aggregate information resulting from your use of the Services.
Using and Sharing Personal Data
Sabai Thai Spa uses Personal Data we collect:
(1) to provide the Services;
(2) to improve the Services;
(3) to communicate with you in response to any of your questions and requests; or
(4) to provide relevant marketing and other information to you, but at all times in
accordance with applicable laws.
Sometime Sabai Thai Spa may be required, or may believe it is required, to share certain
Personal Data with legal authorities. In such a case, Sabai Thai Spa will provide only the
minimum amount of information required and, unless prohibited by law, Sabai Thai Spa will
notify you of the Personal Data it has provided. Such cases include:
(1) if required by law;
(2) to protect or defend against legal liability;
(3) to protect persons from immediate danger, such as personal injury or death; or
(4) to investigate a possible crime, such as fraud or identity theft.
Sabai Thai Spa may share Personal Data with third party service providers as Sabai Thai Spa
deems necessary for such third-party service providers to perform their duties required for the
Services to function. For example, the Services may utilize mail relays, payment processers,
and hosting providers. These third party service providers are not authorized to retain, share,
store or use Personal Data for any purposes other than to provide the services for which they
have been retained to provide in accordance with their respective terms and conditions.
Sabai Thai Spa does not sell or otherwise share Personal Data with unrelated third parties.
Personal Data may be transferred to Sabai Thai Spa’s affiliates, parents, subsidiaries, or as part
of a sale of substantially all of the assets of Sabai Thai Spa. In such a case, each such party
will be required to hold Personal Data and not disclose Personal Data except in accordance with
terms at least as restrictive as those contained in this Policy.
Retention of Personal Data
If we use your Personal Data to make a decision that directly affects you, we will retain that
Personal Data for at least one year so that you have a reasonable opportunity to request access
We will retain your Personal Data only as long as necessary to fulfill the above identified
purposes or for a legal or business purpose.
Using and Sharing Aggregate Information
Sabai Thai Spa uses Aggregate Information:
(1) to provide the Services;
(2) to improve the Services;
(3) to monitor usage of the Services;
(4) to analyze usage of the Services;
(5) to research, compile, and report on usage trends, user demographics, and user
(6) for other legitimate business-related purposes.
Sabai Thai Spa may share Aggregate Information with its affiliates, parents, subsidiaries, and
certain third parties, such as investors, and third-party service providers we use to provide the
Aggregate Information is anonymized and does not have the capacity to be used to identify an
individual. In other words, Sabai Thai Spa may share Aggregate Information provided no
Personal Data will be disclosed to such third parties.
Security and Data Protection
Sabai Thai Spa takes commercially appropriate security measures to protect Personal Data
against unauthorized access, alteration, disclosure or destruction.
Such measures include internal reviews of Sabai Thai Spa’s data collection, storage and
processing practices and security measures, as well as physical security measures to guard
against unauthorized access to systems where Personal Data is stored.
Sabai Thai Spa restricts access to Personal Data to its personnel, service providers, and agents
who reasonably need to know such information in order to operate, develop or improve the
Services. These individuals are bound by confidentiality obligations and are required to treat
such Personal Data confidentially and in accordance with this Policy.
We will take reasonable security measures when destroying your Personal Data, such as
shredding documents or deleting electronically stored information.
Sabai Thai Spa and it’s third-party payment processors may require certain financial
information, such as credit card information, and retain this information for its business
purposes, such as if you wish to pay-by-phone, or other touchless method, or over any self-
checkout application. At all times, Sabai Thai Spa will comply in all respects with applicable
consumer protection laws.
Corrections and Removals
If any part of your Personal Data, such as your name, e-mail address, mailing address,
telephone number or other personal information changes, you may update, correct or remove
the relevant information by contacting Sabai Thai Spa.
You may have the right to access your Personal Data and require Sabai Thai Spa to update,
delete or correct this information, and learn who we shared it with (if anyone). In the alternative,
you may e-mail Sabai Thai Spa for further access and assistance. We will take reasonable
steps to update or correct Personal Data in Sabai Thai Spa’s possession.
A request to correct Personal Data must be made in writing to us and provide sufficient detail to
identify the Personal Data and the correction being sought. If the Personal Data is demonstrated
to be inaccurate or incomplete, we will correct the information as required and send the
corrected information to any organization to which we disclosed the Personal Data in the
previous year. If the correction is not made, we will note your request in our file or system.
If you request information about your Personal Data, we will make the requested information
available within 30 business days, or provide written notice of an extension where additional
time is required to fulfill the request. A minimal fee may be charged for providing access to your
Personal Data. Before we charge any such fee, we will inform you of the cost and request
further confirmation before we proceed. If a request is refused in full or in part, we will notify the
you in writing and reasons for refusal and any recourse available to you.
Contact Sabai Thai Spa
We have a designated privacy officer available to you if you have any questions or concerns
about this Policy. If you would like to contact us about this Policy, or request information, please
do so as follows:
Sabai Thai Spa Inc.
ATTN: Privacy Officer
Mailing address: 2099 Lougheed Hwy, Unit A119, Port Coquitlam, BC V3B 1A8
Effective Date: September 14, 2020.