As Thai Union Property Development Company Limited (the “Company”) is aware of the importance of Personal Data protection, which is the crucial fundamental right of privacy required to be protected according to the law; Therefore, the Company has established a Privacy Policy to ensure that the Company’s operation is in accordance with the Personal Data Protection Act B.E. 2562 (2019) and other relevant laws and to acknowledge the Data Subject of the Company’s Privacy Policy.
This Privacy Policy shall apply to all Personal Data Processing processed by the Company as well as any persons who perceive Personal Data due to their involvement with the Company’s operation shall comply with the laws and this Privacy Policy.
“Company” means Thai Union Property Development Company Limited “Person∏” means a natural person “Data Subject” means a natural person who owns Personal Data “Personal Data” means any information relating to a Person, which enables the identification of such Person, whether directly or indirectly, but not including the information of the deceased Persons in particular “Personal Data Processing” means collecting, using, or disclosing Personal Data “Data Controller” means a person or a juristic person having the power and duties to make decisions regarding the collection, use, or disclosure of the Personal Data “Data Processor” means a person or a juristic person who operates in relation to the collection, use, or disclosure of the Personal Data pursuant to the orders given by or on behalf of a Data Controller, whereby such Person or juristic person is not the Data Controller
The Company shall collect Personal Data which are the sources of Personal Data, the objective and principle of personal data collection shall be as follows.
4.1 Source of Personal Data
4.1.1 Directly collecting Personal Data from Data Subject e.g., the collection of Personal Data from filling the Personal Data via the Company’s documents and/or websites and/or applications and/or forms and/or surveys whether in paper and online formats or by accessing the Company’s electronic system or website system by Cookies.
4.1.2 Indirectly collecting Personal Data from other sources other than the Data Subject e.g., searching Personal Data via the electronic systems or website or via third parties including but not limited to representatives, agents, service providers, business partners, affiliates and/or business alliances. In this case, the Company shall inform and acknowledge the Data Subject without delay and no later than 30 (thirty) days from the date on which the Company collects their Personal Data from such sources as well as proceed to request for their consent in relation to collecting their data, unless it falls under the exception not to request for consents or notify the Data Subject according to Personal Data Protection Act B.E. 2562 (2019) and other relevant laws.
4.2 Objective and Principle of Personal Data Collection, Use and Disclosure
4.2.1 The Company shall process Personal Data to the extent necessary according to its legitimate objective as notified to the Data Subject prior to or at the time of Personal Data collection e.g., for offering the services and products of the Company whether already existing or in the future, for service benefits or product’s improvement, for analyzing and improving the efficiency of services and products, for verification purposes, for analyzing and preparing the documents as requested by any other relevant agencies or organizations or possibly regarding the Company’s business operation, for the Company’s internal management benefit, for the Company’s human resources management, and for the marketing purposes, except the following cases which the Company is allowed to collect Personal Data without the consent request as permitted by laws:
(1) For achieving the objective relating to the preparation of historical documents or archives for public benefit or relating to the research or statistics, the Company shall establish the appropriate preventive measures to protect the rights and freedoms of the Data Subject;
(2) For preventing or suppressing danger to a person’s life, body, or health;
(3) Being essential for performing the contract to which the Data Subject is a party or in order to proceed as per the request of the Data Subject prior to entering into a contract;
(4) Being essential for performing the duty to carry out the tasks for the public benefit of the Data Controller or performing the duty to exercise the state power granted to the Data Controller;
(5) Being essential for the legitimate interest of the Data Controller or of another person or juristic person who is not the Data Controller, except where such interests are overridden by the fundamental rights of the data subject of his or her Personal Data;
(6) for compliance with a law to which the Data Controller is subjected.
4.2.2 In the case where the Data Subject is required to provide their Personal Data for compliance with the laws, the contracts, or it is necessary that the Personal Data be given for the purpose of entering into a contract, or any other reasons, if the Data Subject does not provide such data, it may result in the temporary suspension or discontinuity of transactions or any other activities relating to the Data Subject until the Company receives the Data Subject’s data since the Company is not allowed to process those data, or the laws prohibit the Company to conduct the said transaction or activities.
4.2.3 In collecting sensitive Personal Data, the Company shall request the explicit consent of the Data Subject prior to or at the time of the said sensitive Personal Data collection according to the regulations prescribed by the Company without conflict with the laws.
4.3 Personal Data Collection
Personal Data to be collected by the Company shall include (but not be limited to):
4.3.1 Name, surname, identification number, passport number including copies of such documents;
4.3.2 Contact Data e.g., addresses, copies of house registration, Phone numbers, email address, locations (Geolocation), contact persons in case of emergency, and social media accounts;
4.3.3 Date of birth;
4.3.4 Nationality;
4.3.5 Gender;
4.3.6 Financial Data;
4.3.7 Information regarding one’s preferences in order to analyze the Company's services and products that the Data Subject may be interested in;
4.3.8 Recording from CCTV within the Company's premises;
4.3.9 Other necessary information for verification prior to entering into the transaction, or background check.
The Company shall use and disclose Personal Data according to the objective and principle as stated in Clause 4.2: Objective and Principle of Personal Data Collection. The Company may disclose Personal Data to the extent necessary to the agencies or third parties under the Data Subject’s consent unless the Company performs within the extent permitted by laws. However, the Personal Data may be disclosed to third parties, government organizations or agencies as follows:
(1) Affiliated companies or the companies in the group;
(2) Business partners, parties to the contract, service providers, business alliances of the Company, agents, contractors, assignees, and/or sale agents;
(3) Other third parties such as Facebook, Google Ads, and/or any other marketing agencies;
(4) Agencies that operate credit information, financial institutions, and/or banks;
(5) Government agencies with legal authority;
(6) Any other agencies or organizations that are related or may be related to the business operation of the Company and/or its affiliates or the juristic person according to other laws.
The Company shall store Personal Data for the following period:
6.1 The period as specifically stipulated by the laws regarding the storage of such Personal Data;
6.2 If the laws do not stipulate the specific period for storing such Personal Data, the Company shall store Personal Data as long as it is necessary based upon the objective determined in the processing of Personal Data. The Company shall specify the storage period as necessary and suitable for the Company’s operation; When the said storage period is expired, the Company shall erase, destroy, or anonymize the Personal Data to be the data that cannot identify the individual who is the Data Subject.
The Company shall establish the appropriate Personal Data security measures to prevent theft or breach of personal data, loss, access, use, change, revision, or disclosure of personal data without power or against the laws.
This Privacy Policy is established to assure the Data Subject that he/she can exercise the existing rights under the Personal Data Protection Act B.E. 2562 (2019) as follows:
8.1 Right to withdraw consent. The Data Subject is entitled to withdraw his/her consent on the processing of Personal Data where the Data Subject gives consent to the Company whenever he or she deems appropriate;
8.2 Right to access Personal Data. The Data Subject is entitled to require access to the Data Subject’s Personal Data, request the Company to make a duplicate of the said Personal Data, and request the Company to disclose to the Data Subject an acquisition of Personal Data where the Data Subject does not give consent to the Company;
8.3 Right to rectification of Personal Data. The Data Subject is entitled to request the Company to rectify any incorrect, outdated data, or complete any incomplete data;
8.4 Right to erasure of Personal Data. The Data Subject is entitled to request the Company to erase the Data Subject’s data for certain reasons;
8.5 Right to Restriction of Personal Data Usage. The Data Subject is entitled to request for restriction of the use of the Data Subject’s Personal Data for certain reasons;
8.6 Right to Personal Data Portability. The Data Subject is entitled to request for receiving the Personal Data regarding the Data Subject and request the Company to transmit or transfer to another Data Controller or Data Subject, the Data Subject’s Personal Data previously given by the Data Subject to the Company for certain reasons; and
8.7 Right to Object processing of Personal Data. The Data Subject is entitled to object the processing of the Data Subject’s Personal Data for certain reasons. The Data Subject can exercise the said rights through the channels specified by the Company. However, the Company may deny the exercise of such rights if it appears that there is a reasonable ground which is not against the laws. However, the Data Subject is entitled to submit a complaint to the authorized officer or agency if the Company or the Data Processor violates or breaches the Personal Data Protection Act B.E. 2562 (2019) or any announcements issued by virtue of such Act.
The Company shall consider reviewing the Privacy Policy from time to time.
Name: Thai Union Property Development Co.,Ltd.
Address : 118/8 Rama3 Road, Bang Kho Laem Sub-District,
Bang Kho Laem District, Bangkok 10120