THAI TAKASAGO │ Privacy Policy

This Personal Data Protection Policy of Thai Takasago Group is made to ensure that the Company shall conduct the business by complying with the Personal Data Protection Act, B.E. 2562 (2019) and thereafter amendments, including any applicable laws.
Therefore, the Company hereby announced this Personal Data Protection Policy which pertains to the collection, use, and disclosure of the Personal Data ofan individual who has a relationship or is involved with the Company as follows,

1. Scopeof Application
This policy shall be applied to the Personal Data of an individual who has a relationship or is involved with the Company in some respective way, at present or in the future, whose Personal Data will be processed by the Company, including but not limited to the following person, including but not limited to the following person
    1)     Employee(the employee according to the labor laws),
    2)     Job Applicant,
    3)     Vendor, Contractor, and Service Provider who is a natural person,
    4)     Director, attorney-in-fact, representative, shareholder, employee, or other people who have similar relationships with a juristic person that having              relationships with the Company,
    5)     Website visitors and users, including those in other systems, applications, programs, devices, or other communication and data systems that are under control              by the Company,
    6)     Site Worker,
    7)     Person nearby or within the Company’s office or workplace, or other places that are under control by the Company,
    8)     Other people whose Personal Data is collected by the Company, e.g., employee’ family, job applicant’s family, emergency contact, beneficiary, etc.
In addition to this policy, the Company may announce a privacy notice as a specific policy for each matter or each person in order to notify the data subject of the purpose, legal basis, and retention period, including the rights of the data subject.
In the event of any conflict between the terms of the privacy notice and this policy, the terms of each privacy notice shall prevail.

2. Definition and Meaning

"Thai Takasago Group"
(or the "Company")	means	A data controller who has the power and duties to make decisions
		regarding the collection, use, or disclosure of the Personal Data under
		the terms of this policy, which including;
		(1) Thai Takasago Co., Ltd.
		(2) Thai Takasago Holdings Co., Ltd.

“Data Subject”	means	A natural person whose Personal Data is collected, used, or disclosed
		by the Company under the terms of this policy.

“Personal Data”	means	Any information relating to a natural person, which enables the
		identification of such natural person, whether directly or indirectly, but
		not including the information of a deceased person in particular.

“Sensitive Data”	means	Any Personal Data pertaining to racial, ethnic origin, political opinion
		, cult, religious or philosophical beliefs, sexual behavior, criminal
		records, health data, disability, trade union information, genetic data,
		biometric data, or of any data which may affect the data subject in the
		same manner, as prescribed bythe Personal Data Protection Committee
		under the Personal Data Protection Act , B.E. 2562 (2019).

3. The purposes of the collection, use,or disclosure of the Personal Data
            The Company collects, uses, or discloses the Personal Data for various purposes which depend on the necessity in each circumstance as well as to the extent necessary by the nature of a relationship between the Data Subject and the Company, or by each context. The purposes listed below are only frameworks for all purposes:
    1)     To operate or manage the Company’s business operations according to a contract or a relevant juristic act to which the Data Subject is concerned,
    2)     To carry out the Company’s financial transactions,
    3)     To maintain and update information that concerns the Data Subject, including documents that concern the Personal Data,
    4)     To analyze the data, risk assessment and management, including solving problems related to the Company’s business,
    5)     To carry out the achievement of organization management, including employment, human resources management, employee benefits and welfare,
    6)     To prevent, detect, avoid, and monitor fraud, security breach, or prohibited or illegal activities that may cause damage to the Company and/or the Data Subject,
    7)     To identify, prove, and verify information when the Data Subject is a person who has a relationship with the Company, or when exercising the rights,
    8)     For communication and sending a notification to the Data Subject, including to offer to sell products and services,
    9)     To prepare and providerelevant and necessary documents or information,
    10)   For compliance with applicable laws, notices, ordinances, or proceedings relating to litigation and court order, including the exercise of rights relating to the
             information of the Data Subject,
    11)   To maintain public order, and prevent or stop any harmful causing to the life, body, health, or property of a person.

4. Sources of Personal Data
            The Company collects or acquires various types of Personal Data from the following sources;
    1)     From the Data Subject directly,
    2)     From another company that is in the same affiliated business, or is in the same group of undertakings, in order to jointly operate the business or group of
             undertakings., including but not limited to Takasago Thermal Engineering Co., Ltd., the company incorporated and existing under the laws of Japan.
    3)     From the Data Subject accessing the website which is under control of the Company, or by using other applications, or any other services of the Company,
    4)     From other sources other than the Data Subject provided that such sources have the authority, legitimate ground, or received consent from the Data Subject to
             disclose the information to the Company.

5. Type and category of Personal Datawhichiscollected by the Company
            The Companycollects, uses, or discloses the Personal Data to the extent necessary by the nature of a relationship between the Data Subject and the Company, or by each context, or by other considerations that may affect the collection of Personal Data. The type and category listed below are only frameworks forall Personal Data the Company may collect:

Type and Category of Personal Data	Example and detail
Information of person in particular	The information that identifies the name of the Data Subject or the data from documents issued by the government authorities that identify information of the Data Subject in particular, e.g., title, first name, surname, middle name, nickname, signature, identification number, nationality, driving license number, passport number, house registration, professional license, social security,etc.
Information of person in individualnatureand details	The information relating to the Data Subject in individual nature and details, e.g., date of birth, gender, height, weight, age, marital status, military status, photograph, moving image, language, behavior, preference, bankruptcystatus, incompetent status, quasi-incompetent status, etc.
Contact Info	The contact info of the Data Subject, e.g., home or office phone number, mobile phone number, fax number, email address, address, account name in social networks or online applications (Line ID, MS Teams, etc.), map of a residential place, etc.
Information relating to occupation and education	The information relating to employment including work experience and education,e.g., typeofemployment,occupation, rank, job title, duty,skills, work permit, reference person, tax ID, tenure history, work experience, remuneration and salary, assessment history, benefits and welfares, achievements, educational background, etc
Information relating to property	The information relating to personal property of the Data Subject, e.g., vehicle registration document,or registration documentof propertyin possessionof the Data Subject, etc.
Financial and Insurance	e.g.,account numberand details, informationand detailsof provident fund and insurance policy,etc.
Property and service usage information	e.g., phoneusagehistory,emailhistory,username & password, logfile, location data, photograph, video,sound, behavior tracking data, searchhistory,cookies or other similar technologies, device ID, device info, IP Address, access and connectivity details, browser information,user language, operating system,etc.
Sensitive Data	The Personal Data that is sensitively affect the Data Subject, e.g., racial, religious, health data, disability, criminal records, trade union information, biometric data(e.g., facial recognition data,or fingerprint recognition data),etc.

6. Legal basis for the collection of Personal Data
            The Company, by virtue of one or more of the following legal basis, shall collect the Personal Data to the extent necessary ineach context:
    1)     For compliance with the laws,
    2)     For legitimate interests,
    3)     For preventing or suppressing a danger to a person’s life, body, health, or property,
    4)     For compliance with the contract, or for entering into the contract,
    5)     The Data Subject’s consent.

7.Disclosure of Personal Data
            The Company may disclose the collected Personal Data only for the purposes that the Company informed the Data Subject, or which the Data Subject has given consent, or is permitted by virtue of legitimate ground. The Personal Data may be used by and disclosed to the following persons or organizations to the extent necessary by the nature of a relationship between the Data Subject and the Company, or by each context:
    1)     The government authorities, e.g., court of competent jurisdiction, Royal Thai Police, Ministryof Labor, Department of Provincial Administration, Revenue
             Department, etc. including other private organizations that issued documents relating to Personal Data,
    2)     Contract parties, vendors, or service providers of the Company that carry out activities relating to Personal Data, e.g., bank, financial institution, hospital,
             insurance company, software company, e-service service provider, contractor or sub-contractor, the Company’s hirer, etc.
    3)     Publications, website, application, or social mediathat under control by the Company
    4)     Another company that is in the same affiliated business, or is in the same group of undertakings, in order to jointly operate the business or group of
             undertakings., including but not limited to Takasago Thermal Engineering Co., Ltd., the company incorporated and existing under the laws of Japan,
    5)     Other person, who the Company was given consent by the Data Subject.

8. Sending or transferring the Personal Data to a foreign country
            In the normal operation course of the Company which uses data storage and internet communication technologies, the Company may, to the extent necessary, use and disclose the Personal Data by sending or transferring the Personal Data to a foreign country, e.g. to vendor, contractor, another company that is in the same affiliated business, or is in Page 5 of 6 Latest Updated on 28 th June 2022. the same group of undertakings, in order to jointly operate the business or group of undertakings, and the use and disclosure of the Personal Data by using of email service, office program, cloud storage, server, application, and etc. in which each service provider is mainly operating in a foreign country. Therefore, upon the applicable laws of each country, the destination country or international organization may have inadequate/inconsistent data protection standards compared to the Personal Data Protection Act, B.E. 2562 (2019)

9.Retention period
            The Company shall retain the collected Personal Data for a period that such data is necessary to fulfilled the purposes of this policy, or a minimum period required by laws, or an expected data retention period according the data retention standard by each document, as the case may be, such as the accounting documents shall be retained not less than 5 years from the account closing date or account submitted date, the employment documents shall be retained not less than two years from the date of termination of the employment of each employee, or the legal documents that should be retained not less than each validity period or prescription.

10. Rights of the Data Subject
            The Company shall strictly respect therights of the Data Subject.The Data Subject the rightsunder the provisions of the Personal Data Protection Act, B.E. 2562 (2019) as follows,
    1)     Right to withdraw a consent given,
    2)     Right to access and obtain copy of the Personal Data,
    3)     Right to request to receive, send, and transfer the Personal Data,
    4)     Right to object the collection, use, and disclosure the Personal Data by the Company,
    5)     Right to request to erasure the Personal Data/Right to be forgotten,
    6)     Right to restrict processing of Personal Data,
    7)     Right to rectification,
    8)     Right to file a complaint to a competent authority.

11. The Personal Data Protection Security Measures
The Company shall provide appropriate security measures which are in accordance with the minimum standard specified by the laws for preventing the loss, unauthorized or unlawful access, use, alteration, modification, or disclosure of the Personal Data, and such security measures shall be regularly reviewed at necessary, or when the technology has changed in order to efficiently maintains the appropriate security and safeguard.

12. Information, address, and contact details of the Company
Thai Takasago Co., Ltd.
Bangna Towers C 16th Fl.,
40/14 Moo 12, Bangna-Trad Rd., K.M. 6.5,
Bangkaew, Bangplee, Samutprakarn 10540
Tel. (+66) 2751 9695 – 9
https://www.thaitakasago.co.th

This Privacy Notice is announced at Thai Takasago Co., Ltd.’s principal office (Bangna Towers C 16th Fl.,40/14 Moo 12, Bangna-Trad Rd., K.M. 6.5, Bangkaew, Bangplee, Samutprakarn 10540), and/or on the websitehttps://www.thaitakasago.co.th, and/or posted on nearby or within the Company’s office or workplace, or other places that are under control by the Company, the Privacy Notice may be changed, reviewed, or amended from time to time by announcement or by informing to the parties concerned.

Latest Updated on 28th June 2022.

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