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(a) For our clients or associated persons, we collect various types of data from you, which can be used to identify you as an individual, whether directly or indirectly (“Personal Data”), including your full name, home address, personal email address, contact number(s), place of work, job title, business email address, data contained in your identification document (e.g. identification card, passport, or driver’s license), signature, and any other Personal Data you may provide to us. The national identification card we collect from you may contain Sensitive Personal Data, i.e. blood type and/or religion;
(b) For prospective clients, the Personal Data that we collect will normally depend on how you contact us and the purpose of such contact, which may include your full name, personal or business email address, mobile phone number, and your place of work;
(c) When you visit our office, we will collect details pertaining to your full name, place of work, contact number(s), and car license plate number, as well as photos or motion images recorded by CCTV;
(d) In the event that you contact us via any social media platform, including, without limitation to, Facebook and LinkedIn, we may collect Personal Data which you have provided to us via such platforms. Notwithstanding that, in the case where you contact us via social media platforms, Tilleke is not responsible for the privacy or the information security practices of such platforms. Therefore, you should carefully review the applicable privacy and information security policies and notices, for any of the websites/platforms that you use; and
(e) In certain circumstances, we may collect the Personal Data of your family member(s) such as your spouse and children, which may include Personal Data of minors, who are under 20 years of age, when it is necessary for us to provide our legal services, including, without limitation to, services related to family law matters, immigration, and work permits.
3 Why does Tilleke collect and process your Personal Data?
Tilleke collects your Personal Data for different purposes, relying on various lawful bases, as set out below:
(d) Legal Claims: For the establishment, compliance, exercising, or the defense of Tilleke’s legal claims.
(a) Directly from you: We normally collect your Personal Data directly from you (the “Data Subject”), when you contact, communicate, or correspond with us either via email or through direct interaction. For example, we may collect your Personal Data when you register to attend a seminar, or for training, or for any event which is hosted/provided by us, or when you contact us for legal or other business inquiries.
(b) Referring persons: We may collect your Personal Data from other persons, such as our partner firms, business partners, relevant associations and existing clients, which are permitted to contact us, or to introduce or refer you to us.
(c) Public sources: We may collect your Personal Data which is available on public sources, such as websites that are provided by authorities (e.g. the Department of Business Development), or via websites which are provided by private operators.
(d) Employer or others: In the case of corporate clients, we generally collect the Personal Data of associated persons through your employer or directly from you, in order to provide our services and to maintain our relationship with you.
Depending on the service we are providing to you, we may disclose your Personal Data to the following parties:
We regularly transfer your Personal Data to our affiliates, and in certain circumstances, to third parties (e.g. service providers), which are located outside Thailand, and which may have different data protection standards to those prescribed by the data protection authority in Thailand. Notwithstanding that, we ensure that we will protect your Personal Data by implementing adequate personal data protection standards for the transfer of your Personal Data outside Thailand. We will also ensure that any entity to whom your Personal Data will be disclosed will implement adequate personal data protection standards, and where your Personal Data will be transferred within our affiliates, we will use the relevant data transfer mechanisms in accordance with the requirements of the PDPA.
The majority of the transfers of your Personal Data are undertaken for the purpose of the provision of our services and the management of our business. In addition, your Personal Data is mostly transferred to our affiliates, which are located in Cambodia, Indonesia, Laos, Myanmar, and Vietnam.
In all cases, we will transfer your Personal Data only where it is permitted and in compliance with the PDPA.
We retain your Personal Data for as long as is required in order to fulfil our contractual obligations, or for the performance of our services to you, and for 10 years after the cessation of our contractual relationship, or the last performance of our services, unless otherwise agreed with you in writing, or required or permitted by applicable law.
Where we process your Personal Data in connection with a legal obligation, your Personal Data will be retained for the duration of the prescribed legal retention period, as stipulated under the applicable law.
Where we process your Personal Data solely with your consent, your Personal Data will be deleted, destroyed, or de-identified, subject to the requirements and conditions prescribed by the applicable law.
You are entitled to:
(a) Request to have access to and obtain a copy of your Personal Data, and to request the disclosure of the source of the Personal Data, in the event that your Personal Data was collected without your consent;
(b) Receive your Personal Data in a commonly used and machine-readable format, and to have your Personal Data in said format transmitted to another Data Controller;
(c) Request that your Personal Data be deleted, destroyed, or de-identified;
(d) Object to the collection, use, and disclosure of your Personal Data, and especially where such collection, use, or disclosure is for direct marketing purposes;
(e) Request that the processing of your Personal Data be suspended;
(f) Request that your Personal Data be corrected, updated, or completed;
(g) Withdraw your consent at any time, provided that there is no other legal ground for Tilleke to continue with the processing of your Personal Data; and
(h) Lodge complaints to the competent authority.
Your request may be refused, and the exercise of your rights is subject to the limitations prescribed by law.
If you have any inquiries in relation to your Personal Data, or you would like to exercise any of your Data Subject rights, you may contact us at:
Tilleke & Gibbins International Ltd.
Supalai Grand Tower, 26th Floor
1011 Rama 3 Road, Chongnonsi, Yannawa
Bangkok 10120, Thailand
T: +66 2056 5555
Or you may contact our Data Protection Officer at:
T: +66 2056 5650