Personal Data Protection Policy

Purpose

This policy is intended to inform you as a data subject of the purpose and detail of how we collect, use and disclose personal data. This also include your right as provided by law in regard to personal data.

Personal Data we collect, use or/and disclose

“Personal Data” means any information relating to a natural which enables the identification of such natural person, whether direclty or indirectly, but not including the information of the deceased person in particular, such as personal data given to the company directly or via other channels; which is not from you directly, such as government organization, financial group, financial instiutions, financial advisors, allies, credit bureau and information service provide. We shall only collect data from third party when we obtain your consent unless it is neccessary as provided by law.

Personal Data can include:

  • Personal information such as name, last name, age, date of birth, marital status, ID number, passport number
  • Contact Information such as address, workplace, telephone number, email address, line ID
  • Employment Information such as employee ID, position, job description, line of command, employment terms and conditions (e.g. wage/salary, other benefits, social insurance information, retirement information, provident fund, tax information, beneficiaries, work evaluation, history of filing complaints, history of leave and absence, health information, physical checkup information, or workplace information and safety, investigation and risk assessment, image and voice information of the employee for disciplinary process or collecting as an evidence for an ongoing investigation. Criminal record in case of being required by law in certain situation.
  •   History of health information health examination and health status or health behavior information related to working in an establishment, including inspection and risk assessment.
  • Qualification and Work Experience such as certificate, diploma from school, university, academics record, academic test or language, letter of recommendation
  • Financial Information such as bank account number, credit card Number, debit card number
  • Electronics Device of Equipment which owned by the company or personal belongings that has been used in the company such as IP address MAC address Cookie ID
  • Other Information such as website browsing, voice, images, motion images or other personal information as defined in Personal Data Protection Act

Company may collect, use, or disclose sensitive personal data which is specifically defined by law only when receiving an explicit consent or as being required by law. Company may collect, use or disclose personal data which relates to nationality, race, political view, religious belief, or philosophy, sexual behavior, criminal records, health information, disability, union, genetics, biometrics data such as face image, fingerprints or others. 

Purposes of Data Processing

Company shall process your personal data to fulfill contractual execution with the company, purchasing goods and services of the company, fulfill legal obligation, or others which required by this policy as follows;

  1. Fulfilling obligation or conditions as stated in the contract which you have entered with the company, fulfilling a transaction such as purchasing goods and services or proceeding as requested prior to purchase     of goods and services such as;
    1. Considering on qualification of job applicants with the opening position in the company
    2. Considering credit assessment such as credit approval, investment, insurance, exchange, payment or property.
    3. Fulfilling a transaction which relates to provide goods and services such as processing, contact, notification, sub – contract to third parties, transfer of right and responsibility, payment reminder, product or services renewal, debt collection
  2. Pursuing any activities as necessary under the rules of company, other people or other legal entities with legitimate interest such as;
    1. CCTV footage, fingerprint scan or exchanging the ID card with visitor card to protect your personal belonging and company’s property.
    2. Maintaining relationship with customers such as handling complaints, customer’s satisfaction survey, sending out reminder or present customers with goods and services which will benefit the customers
    3. Risk management, supervision and internal management, or transfer of information to the affiliates under Binding Corporate Rules
    4. Anonymization of data
    5. Taking steps to prevent, handle and reduce other risks which may happen from fraud, cyber crime, default, contract violation, illegal activities; such as offences against property, life and body, liberty or reputation. This shall include sharing personal data to lift up the working standard of the company and affliates.
    6. Collection, use or disclosure of personal data of committee, authorized person, representative of legal entities.
    7. Communication, image capturing, voice recording which relate to meeting, training, recreation, and booth exhibit .
    8. Collection, use or disclosure of personal data whose assets confiscated by court order
    9. Receiving and delivery of parcels, company’s document or email)
  3. Compliance with legal obligation such as:
    1. Compliance with orders of authorized person.
    2. Compliance with legal obligations such as labor law, life insurance law , non-life insurance law, tax and duty law, anti-laundering law, anti-terrorist and anti-weapon of mass destruction law , computer law, bankruptcy law and other applicable laws to which company are subjected internally or internationally.

In certain circumstances, where a data subject does not provide personal data which is required to fulfill legal or contractual obligations, the company will not be able to perform the obligation under the contract to which you are a contracting party or not be able to deliver or provide the products and services if the personal data has not been collected when requested.

Who we share your personal data with

When receiving personal data either directly from you or third parties, company shall disclose your personal data which we seek for your consent earlier or other purposes permitted by law with third parties. The disclosure of your personal data to the the above persons and entities shall be in accordance with the Purposes as you agreed in this policy. 

The Company shall disclose your personal data for the purposes as set out in this policy such as to provide you services, to analyze and improve products and  services, reseach and statistical information, administration, prevent from corruption,  or to ask for support from other people, to prove customer’s identity. The company shall disclose the personal data to the following persons and entities such as company’s affiliates, , personal data processor, allies which company has co-brand with, outsiders, company’s representatives, sub-contractor, financial institution, , auditor, external auditor, legal authortities, legal entities or person who is in contacted or contracted with the company, including its management, staff, employee, sub contractor, representatives or consultant.

In the event that the company shall disclose to third parties for the marketing purpose of the data recipients, the company shall notify you the list of recipients for your approval. 

Cross Border Transfer

In the event that, the company has to transfer your personal data to affiiates in other countries or other recipients; in regard to normal activities, such as transmit or transfer your personal data to store in their server or cloud in other countries.

In case the personal data are transferred to the countries that will not have adequate data protection,             the company shall ensure the transfer of personal data will meet with standard as required by law and also apply necessary and appropriate measures of personal data protection to meet with confidentiality                                                                     standard of personal data; such as arranging an agreement with the data receiver in overseas, or shall implement personal data protection policy which has been verified and certifited by legal authorities and transmit or transfer personal data to other contries in lieu of compliace with law.

How we store your personal data

Company shall store your personal data by applying an appropriate organizational measures, technical measures, and physical measures to retain confidentiality, integrity and availability to prevent personal data violation. The company has set out the policy, regulations, or rules of personal data protection such as IT security policy, preventive measures to prevent the recipients from processing data out of the area set out in the policy or without power or authority. Company will review the policy, regulation, rule from time to time where it is necessary and appropriate.

Futhermore, executives, staff, employee, sub-contractor, representative or consultant also has responsibility to maintain confidentiality of personal data as provided in this policy

How long we will store personal data for

Company shall retain your personal data for as long as it is necessary while you are contracting with company such as being employed, being a customer, or in relationship with the company, or as required to pursue the objectives set out in this policy. In certain circumstances, company may need to  be retain your data for a longer period of time, if it is required or permitted by law such as labor law, the anti-money laundering law. However, we shall retain your personal data for the purposes of verification if there may are legal disputes as long as required by law but not longer than 10 years.

  Company shall delete or destroy your personal data or anonymize your data when it is no longer required or reach the end of the period.

 

What are your rights in relation to personal data

Under the PDPA, you are entitled to these following rights that you will be able to exercise provided by law and this policy now or in the future; and other regulations as provided by company. If you are younger than 20 years old or not capable of performing legal actitvites by yourself, you shall request your parents, legal guardian for acting on your behalf to make a request. 

1. Right to withdraw your consent: If you have given your consent to the company to collect, use or disclose your personal data; whether it is prior to the effective date as stated on Personal Data Protection Act or afterward, you have the right to withdraw your consent as long as your personal data is in company’s possession unless there is a restriction provided by law or there are some contract that you are still benefit from it. However, withdrawl of your consent may interrupt the company from fulfilling contractual obligation as agreed or perform as described in the contract between you and the company or providing goods and services such as you will no longer received latest benefits, promotion or offers which is better and be in your interest or useful information. You should do your research and questions of what may affect you if you withdraw your consent

2.Right to access: You have the right to access your personal data which in company’s posession, receive of a duplicate of your personal data or disclose how the company obtain your data.

3.Right to Data Portability: You have the right to receive a copy of personal in a machine-readable form and also use or disclose in automatic form and have the right to transmit those data to another controller where the processing is carried out by automated means. The data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

However, Personal Data as referred above shall be your personal data given  consent to the company to collect, use or disclose to fulfill contractual obligation or condition as agreed in the contract to provide goods and services as intended or other personal data as provided by legal authorities.

4.Right to Object:

          You have the right to object collection, use and disclosure of personal data at any time if the personal data has been collected to fulfill their obligation as necessary under the law of company or third parties with legitimate interest or for public interest. However, the company may be able to continue collecting, profiling, using or disclosing your personal data only those which the company can demonstrate compelling legitimate ground which override your basic rights or to confirm your right based on law, compliance with law, or prosecution. 

You also have the right to object collection, use or disclose of your persona data for marketing purpose, scientific, historical or statistical purposes.

5. Right to Erase:

You have the right to delete or destroy your personal data, anonymize your personal data if your believe that your personal data has been collected, used or disclose illegally or is no longer needed to retain this personal data as set out in purpose of this policy, you have already withdraw your consent or object as descibed above.

​​6. Right to Restrict :

You have the right to restrict the processing of personal data while personal data are being rectified or objected by you or in the event that the company no longer need this information and shall erase or destroy personal data as provide by related law but you have asked for restriction instead.

 

7. Right to Rectify: You have the right ask for rectification of your inaccurate data to be correcred, updated and completed and do not cause misunderstanding.

8. Right to lodge a complaint: You have the right to lodge a compliant to authorise people if you believe that the collection, use or disclosure of you personal data may violate related law

9. These rights as mentioned above may be limited under the related law and in some certain circumstances that company may not be able to proceed as you request; due to fulfil the legal obligation or court order for public interest; to proceed as your request may violate rigt and liberty of other people. If the company shall not be able to proceed, we will notify you the reason for declining your request

However, If you would like to exercise your right, you can contact our DPO/responsible persons to proceed your request to exercise your rights as shown above through the contact address as shown below. Company will consider and notify you within 30 days after receiving your request.

How to contact us

If you have any suggestion or questions regarding the detail of how to collect, use or disclose your personal data, including

1. Mr. Doonyapinit Posorn     Position: General Manger (General Affairs & Human Resources Department)

  Email:  Doonyapinit.p @fujitsu.com         Tel. 02 – 501 1100 Ext.120

Contact Address :  Transtron (Thailand ) Co.,Ltd.

136  Moo 5 , Bangkadi Indutrial Park, Tiwanond Road, Tambon Bangkadi, Amphur Muang, Pathumthani 12000.

Changes to this policy

From time to time, Company may review or update this policy to comply with law or changes in technology that the company shall use to process personal data; also include the security of personal data protection. We recommend you periodically follow up or check on personal data protection policy which shall be posted on the the board of notice so that you will be aware of the change in this poilcy.  If there is any change or updated of this policy, we will note as “Updated” company’s board.  

This policy will be in effect on  23nd December, 2024 so forth.

Request Form for Exercising Data Subject Rights