(Updated: June 2022)
PriceSanond Limited (“PSL”, “we”, “us” or “our”) are committed to upholding all obligations under the Personal Data Protection Act, B.E. 2562 (C.E. 2019) (the “PDPA”).
This Privacy Notice describes how we may collect, use, share, and otherwise process (collectively “process”) personal data (defined below) and explains your rights in connection with such personal data.
This Privacy Notice applies to all processing of personal data, irrespective of whether we or any third parties process the personal data. This Privacy Notice should be read, comprehended, and periodically revisited by all related parties to ensure a complete understanding of the procedures to process personal data.
For purposes of this Privacy Notice, “personal data” means any information relating to a living individual who can be identified from that data or from that data with other data as described below.
This Privacy Notice shall apply to data subjects who (i) visit our website, our social media, or other online presences; (ii) contact us through any channels, such as email, telephone, online calls, facsimile, hand delivered information, courier, post, website, social media, or other presences; (iii) engage our legal and related services; and/or (iv) provide goods or services to us.
What Types of Personal Data We Might Collect
Personal Data. Any data relating to a living individual that could directly or indirectly identify that individual, including but not limited to:
|Basic data||Such as full name, nickname, signature, title, position, job responsibilities, photograph, date of birth, place of birth, age, marital status, gender, nationality and including all personal data in a copy of ID card, passport, driver’s license or similar identifiers|
|Contact data||Such as postal address, telephone number, email address, or ID used for various messaging services|
|Social media data||Such as posts, likes, shares, or other interactions with our social media presence|
|Public sources data||Such as Linkedin and similar professional networks, directories, or internet publications|
|Billing and financial information||Such as billing address, bank account, credit card, or other payment information|
|Marketing and communication data||Such as communication preferences or marketing opt-ins|
|Event data||Such as attendance at and provision of feedback forms in relation to our events|
|Usage data||Such as your usage data on website navigation or most-visited parts of our websites, or your use of our networking facilities, WIFI, or similar electronic services|
|Supplier data||Such as contact details and other data about your company’s or organization’s personnel where you provide services to us|
|Audio and video recording data||Such as closed-circuit television (CCTV) recordings, audio recordings, online meetings, webinars, or other information obtained through electronic means|
|HR information||Such as performance and evaluation, educational background, qualification/license, title, professional background, disciplinary punishment/official commendation, criminal records, training records, remuneration, welfare and benefits information, workmen’s compensation and social security information, medical claims, group insurance information, provident funds, personal income tax, health condition, medical records, physical or mental disabilities, results of a health checkup or other information relevant to the course of human resource management|
|Other data||Such as, but not limited to, any other data as necessary or relevant to the provision of our legal and related services such as racial, ethnic origin, political opinions, beliefs, religious or philosophical beliefs, sexual behavior, criminal records, health data, disabilities, trade union information, genetic data, biometric data or of any other data which may affect you in a similar manner|
From Whom We May Collect Personal Data
Data Subjects. Any individuals (collectively, “you” or “your”) who:
- contact us via e-mail, telephone, internet voice or video call, website or other means of any kind; and/or
- engage our legal or non-legal services; and/or
- are employed by us or under consideration of employment; and/or
- are our suppliers or contractors.
We may collect your personal data directly from you or your representative or indirectly from third parties, e.g., your outsourcers, service providers, advisors, or government agencies.
How We May Collect Personal Data
We may collect your personal data through the following processes:
- Communicating with you or your representative through any type of communication method; and/or
- Review of any information or documents provided by you or your representative; and/or
- Searching on publicly available sources, including, but not limited to, online databases of courts or any other government agencies.
How We Use and Process Personal Data
We may use your personal data for one or more of the following reasons:
- providing our legal and/or other relevant services and/or performing under relevant client, supplier, vendor, employment, or other contracts;
- performing conflict checks or background checks;
- contacting relevant government or other authorities on your behalf;
- managing billing and collecting fees, reimbursements or payments; or
- marketing or marketing strategies, updates, campaigns, promotions, newsletters, invitations, seminars, webinars, training, customer care or other relevant activities.
Apart from the above, we rely on the following lawful bases for our processing of personal data:
- Legal Obligation. Performing a legal obligation to which we are subject;
- Contractual Basis. Performing our obligations, or exercising our rights, under our contracts or understood engagement with you or to take steps at your request prior to entering into a contract or understood engagements;
- Public Task. Performing a task in the public interest or for the exercise of official vested authority;
- Legitimate Interests. Pursuing our legitimate outweighing interests and those of third parties; or
- Consent. Obtaining your consent in the event any of the above underlying lawful bases do not apply.
How Long Do We Keep Personal Data
We will keep your personal data only to the extent necessary for its purposes, under prudent record keeping and case information retention, or under legal requirements.
Sharing of Personal Data
Personal data shall be kept confidential as prescribed by law and in accordance with the purposes specified above. However, in rendering our services, we may be required to share your personal data with the following parties;
- Parent/affiliates of your company/employer;
- Counterparties, their representatives, lawyers, or other designated persons;
- Online publishing and ranking companies and social media platforms;
- Business partners and outsourcing service providers such as marketing, IT support, security providers, advertising or communications agencies and cloud service providers;
- External auditors;
- Governmental agencies or instrumentalities; and/or
- Financial institutions for payment or other transactional purposes.
Where personal data is shared with third parties, we will ensure that the minimum amount of personal data is shared and ensure the protection of your personal data, such as confidentiality arrangements and appropriate security measures to the extent required by law.
How Do We Keep Personal Data Safe
We have engaged professional IT support and security and implemented system audits to ensure continuous security measures to protect against unauthorized access to, use, alteration, correction or disclosure of personal data.
Your Personal Data Rights
Your rights under the PDPA, include the following:
- Right to To request access to and obtain a copy of the personal data related to you which are under our responsibility as a personal data controller, or to request for disclosure of how the personal data was obtained without your consent;
- Right to Rectification. To require us, as a personal data controller, to take action to ensure that the personal data are correct, updated, complete and not misleading;
- Right to Portability. To request to obtain personal data in the event that we, as personal data controller, have made the personal data available in a format which is generally readable or usable by automated tools or devices and where the personal data may be used or disclosed automatically;
- Right to Object. To object to the collection, use, or disclosure of your personal data which are legally permitted to be collected without the personal data subject’s consent at any time;
- Right to Delete. To request us, as personal data controller, to delete or destroy your personal data or make the personal data subject unidentifiable from the personal data in cases prescribed by law;
- Right to Suspend. To request us, as a personal data controller, to suspend the use of personal data in cases prescribed by law;
- Right to Withdraw Consent. To withdraw consent at any time, subject to the requirements of the PDPA; and
- Right to File a Complaint. To file a complaint to the relevant committee under the PDPA if we, as a personal data controller, or any personal data processor, including any employee or contractor of a personal data controller or a personal data processor, violates or fails to comply with the personal data protection laws.
HOW TO CONTACT US
If you have any questions concerning this Privacy Notice, please contact us as follows:
|Price Sanond Limited|
|Address:||16th Floor, Q House Sathorn,
11 South Sathorn Road,
Bangkok 10120 Thailand
Please note that this policy may be updated from time-to-time and should be read with any other specific privacy notice we may occasionally provide on a case-by-case basis.