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Personal Data Protection Policy for Video Surveillance

This Personal Data Protection Policy for Video Surveillance (“Policy”) explains how Tilleke & Gibbins International Ltd. and our Affiliates (collectively “Tilleke”, “we”, “us” or “our”) collect, use, disclose, transfer, and otherwise process (“process” or “processing”) your Personal Data in the course of our business, in accordance with the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”).

We advise you to read this Policy in its entirety.

1. When does this Policy apply to you?

This Policy applies to all individuals, including our employees, clients, prospective clients, vendors, suppliers, and any other members of the public, entering Tilleke’s premises.

2. What types of Personal Data does Tilleke collect and process from you?

We use video surveillance at our premises to monitor and record your images and videos, every day, 24 hours per day.

Where Tilleke will collect other categories of personal data, we will inform you of such collection and, if required by applicable law, obtain your consent, in accordance with the provisions of the PDPA.

Please note that our video cameras are located only in public areas.

3. Why does Tilleke collect and process your Personal Data?

In general, we will process your personal data for the following purposes:

 

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  1. In the case where we will process your personal data for purposes other than those prescribed in this Policy, we will inform you about such new purposes and, if required by applicable law, obtain your consent, before we process your personal data for such new purposes.

4. Where does Tilleke collect your Personal Data?

Tilleke will collect the personal data directly from you through the video footage. 

5. To whom does Tilleke disclose your Personal Data?

Tilleke may disclose your personal data to the following third parties: 

  • (a) To any of our affiliates or group companies, both within and outside Thailand, for internal record and for other purposes as identified in this Policy;
  • (b) To external legal counsel, advisors, auditors, and other experts;
  • (c) To third-party vendors, suppliers, or service providers, who provide services to us, such as video system suppliers, outsourced system developers, etc.;
  • (d) To any other persons or entities to whom Tilleke is required to make disclosure by applicable law, or to whom Tilleke is permitted by you to disclose your personal data; and/or
  • (e) To government agency, authority, court, or competent official pursuant to the applicable laws, regulations, or orders to which we are subject.

6. Where does Tilleke transfer your Personal Data?

Tilleke may transfer, disclose, and give access of your personal data to our affiliates and group companies located outside Thailand and in certain circumstances, to third parties, for processing of personal data for the purposes specified in this Policy. The destination countries may have different data protection standards to those prescribed by the data protection authority in Thailand. Notwithstanding this, Tilleke will ensure to protect your personal data by implementing, and requiring the recipient to implement, adequate personal data protection standards for the transfer and processing of your personal data as required by the PDPA.

7. For how long does Tilleke retain your Personal Data?

Tilleke will retain your personal data for as long as necessary to achieve the purposes described in this Policy. In general, we will retain your personal data for 30 days, unless otherwise permitted or required by applicable law.

8. What are your rights in relation to your Personal Data?

Subject to the conditions and limitations imposed by the PDPA, you have the following rights

with respect to your personal data:

  • (a) To withdraw your consent;
  • (b) To request to have access or to obtain a copy of your personal data, and to request that we disclose the source(s) of your personal data which has been obtained without your consent;
  • (c) To request that we correct or update any personal data;
  • (d) To request that we delete, destroy or de-identify your personal data;
  • (e) To object to the processing of your personal data;
  • (f) To request to receive your personal data in a format which is generally readable or usable by automatic device or tool (if any), and to have your personal data in said format transmitted to another data controller; and
  • (g) To request the suspension of the processing of your personal data.

In addition to the rights above, you also have the right to file a complaint in relation to our processing of your personal data with the Office of Personal Data Protection Commission in accordance with the procedures set out in the PDPA. As far as permitted by the applicable law and regulations, we may be entitled to charge reasonable expenses incurred in respect to handling any of the above requests.

9. Changes to this Policy

Tilleke may amend, change, or update this Policy from time to time, whereby Tilleke will notify you about such changes via your selected communication channel or any other communication channels as Tilleke deems appropriate. In the event that the amendment, change, or update will affect the purposes for which your Personal Data has originally been collected, Tilleke will notify you about such changes and obtain your consent (if applicable), prior to such changes becoming effective.

10. How can you contact us?

If you have any inquiries in relation to your Personal Data, or you would like to exercise any of your 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

F: +66 2056 5678

Email: [email protected]

 

Or you may contact our Data Protection Officer at:

 

Papitchya Supinananda

T: +66 2056 5555

F: +66 2056 5678

Email: [email protected]

 

This Policy is effective from June 1, 2022, onward.