Privacy notice

Privacy Notice for Customers, Trade Partner, Person Having Business Relation, Operator in PTT Group

P-DICTOR Company Limited (hereinafter referred to as “P-DICTOR” or “we” or “our”) gives highest priority to the protection of the personal data of the Customers, Trade Partners, the Persons Having Business Relationship and the Operators in PTT Group (collectively referred to as “you”), and in order for you to ensure that we will protect and manage your personal data in accordance with the laws concerning personal data protection, we then established this Personal Data Privacy Notice for your acknowledgement of details of the processing of personal data, whether it be the collection, use and disclosure (collectively referred to as the “Processing”) that may be occurred and including to inform you of the rights on your personal data and our contact channels.‍

1. Types of persons that we collect the personal data

Under this Personal Data Privacy Notice, P-DICTOR shall collect the personal data of the following persons:

1.1 “Customer(s)” means the person who will purchase or purchases product and/or obtain service from P-DICTOR, or other persons who contact and inquire for information of product and/or service of P-DICTOR, the person receiving information of product and/or service through relevant media and the person receiving advertisement and public relations concerning product and/or service of P-DICTOR, and shall mean to include an ordinary person who is related to or is an agent of the juristic person which is a customer such as the executive, director, employee, hired staff, agent, representative or any other ordinary person, and the person having his/her personal data appeared in relevant documents in relation to the conducting of transaction between P-DICTOR and such juristic person such as the coordinator, the person issuing purchase order, the person receiving product and the cheque payer, etc. including a person that such juristic person has provided data for P-DICTOR.

1.2 “Trade Partner(s)” means the person who will sell or sells product and/or provide service for P-DICTOR, whether it has been registered as the trade partner of P-DICTOR or not, such as the contractual party, service provider and advisor, etc. and shall mean to include an ordinary person who is related to or is an agent of the juristic person which is a trade partner such as the executive, director, employee, hired staff, agent, representative or any other ordinary person, and the person having his/her personal data appeared in relevant documents in relation to the conducting of transaction between P-DICTOR and such juristic person such as the coordinator, the person delivering the product and the cheque payer, etc. including a person that such juristic person has provided data for P-DICTOR.

1.3 “Person(s) Having Business Relation” means the person which is not a customer, trade partner or the operator in PTT Group that has relationship in the manner relating to the conduct of business such as the person who performs work in the government authority which regulate the conduct of business or supervise the compliance with laws, the person interested to participate in business project or the business project participant, the person interested to make a joint investment or the co-investor, the agent or broker for the procurement of product or service for P-DICTOR, and shall mean to include an ordinary person who is related to or is an agent of such juristic person such as the executive, director, employee, agent, representative or any other ordinary person, and the person having his/her personal data appeared in relevant documents in relation to the conducting of transaction between P-DICTOR and such juristic person.

1.4 “Operator(s) in PTT Group” means the director, employee or other personnel of the companies that PTT holds shares and shall mean to include an employee of the companies that PTT holds shares which performs work at P-DICTOR pursuant to the policies or rules of P-DICTOR.

2. Purposes for the collection, use and disclosure of personal data

2.1 In general, whether you are a Customer, Trade Partner, the Person Having Business Relationship or the Operator in PTT Group, P-DICTOR may proceed on the Processing of your data

on the following purposes:

Clause	Purposes	Lawful Basis
1	For contacting and coordination in relation to the business operation of P-DICTOR.	Legitimate interest basis
2	For the collection and use of your personal data such as name-surname, position, work unit and picture-video in relation to the operations and activities of P-DICTOR for dissemination or public relations through relevant channels such as internal email of P-DICTOR and group companies, P-DICTOR’s website, Facebook, LINE, YouTube or other online media of P-DICTOR or other media such as television and publication, etc.	Legitimate interest basis
3	For using as information on the application for using electronic system or enabling the right to access or use internet or relevant electronic systems.	Legitimate interest basis
4	For the business planning, reporting and estimation, risk management, audit supervision including the internal audit of the internal audit office and internal management in the organization, including for the benefit of internal operations within P-DICTOR in relation to the disbursement of payment of the accounting and finance unit of P-DICTOR.	Legitimate interest basis
5	For using as information in the proceedings in relation to Know Your Customer and/or Due Diligence concerning P-DICTOR’s operation including the due diligence investigation on the status of business or other types of profile inspection for evaluation on the appropriateness or risk assessment before making a decision to enter into relevant transactions together with identity proof and verification or the verification of authority, the granting and obtaining of authority for the execution of any agreement or contract with P-DICTOR.	Legitimate interest basis
6	For the proceedings in relation to the assignment of any right, duty and benefit such as merger and acquisition, separation or business transfer which has duly been conducted in accordance with the laws.	Legitimate interest basis
7	For using as database of the stakeholders of P-DICTOR and/or using as an information for relationship management or relevant coordination in relation to P-DICTOR including opinion survey for analysis and improvement of PTT’s operation.	Legitimate interest basis
8	For the disclosure of information necessary for the compliance with relevant evaluation criteria participated by P-DICTOR.	Legitimate interest basis
9	For the investigation and inquiry of the complaint in the organization, corruption prevention or any other legal proceeding including the inspection and administration of complaints and allegations in relation to the operation of P-DICTOR or the related person for transparency and justification of all parties.	Legitimate interest basis
10	For accepting the application or consideration on the participation in relevant projects or activities of P-DICTOR such as field trip activity, technical visit, site visit, receiving donation, seminar, training project or other projects of P-DICTOR or the projects that P-DICTOR proceeded in cooperation with the third parties or government authorities, etc. as well as the relevant proceedings in relation to the activity participation such as answering quiz for reward, the delivery of reward, the proceeding for management and administration concerning your heath, hygiene and safety such as the arrangement of health insurance for participating the field trip, etc. including for the evaluation, analysis and improvement of such projects or activities.	Legitimate interest basis
11	For maintaining security in building area, premises and gas stations of P-DICTOR including the exchange of cards for the entry and exit of such area, the recording of videos of the visitors of P-DICTOR or the buildings, premises and gas stations of P-DICTOR by closed-circuit television (CCTV).	Legitimate interest and legal obligation basis
12	For the establishment of legal claim, the granting or obtaining of authority, the compliance, exercise or defense of legal claim and relevant legal proceedings as well as the proceedings for legal execution.	Legitimate interest and legal obligation basis
13	For compliance with laws or compliance with court’s summon, letter or order of authorities, independent organizations or officers having duties and powers under the laws such as the compliance with a summon, writ of attachment, order of the court, police officers, public prosecutors and government authorities including the reporting or disclosure of information to the shareholders, government authorities or independent organizations such as Energy Regulatory Commission, Ministry of Energy, Revenue Department, Land Department, State Audit Office, the Office of National Anti-Corruption Commission, etc. for compliance with relevant laws.	Legal obligation basis
14	For the compliance with laws concerning public interest in respect of public health such as health protection against dangerous communicable disease or epidemic which may be contagious or spread into the kingdom.	Legal obligation basis
15	For the management and administration concerning your heath, hygiene and safety.	Preventing or suppressing danger to a person's life, body or health (Vital Interests)
16	When you use our online social media such as Facebook, LINE, YouTube and other online media, P-DICTOR may collect, use or disclose your personal data pursuant to the following purposes: For the performance measurement and the analysis on market survey and market strategies including for business planning, reporting and estimation; For opinion survey, analysis, research and development of products, services and activities of P-DICTOR to be more suitable with your requirement and for the development of communication and public relations to be suitable with your requirement; For the risk management, audit supervision including for the internal audit of the internal audit office and internal management and administration in the organization such as for inspection and prevention of corruption, etc.; For contacting in order to request for additional information, complaint inspection, complaint management, performance record keeping and the proceedings in accordance with internal procedures of P-DICTOR; For selection of activity participants, answering quiz through online channels, announcement of activity result, giving of rewards to participants in accordance with conditions prescribed by P-DICTOR as well as keeping as database of the profile of activity participants of P-DICTOR; For the compliance with laws, investigation and inquiry pursuant to legal proceedings and any other rule and regulation and for reporting or disclosure of information to government authorities or any other organization by the virtue of the laws or the court’s order including for the establishment, compliance, exercise or defense of legal claim.	Legitimate interest and legal obligation basis

Other than the above purposes, P-DICTOR may further proceed on the Processing of your personal data for the relevant cases as follows:

2.2 In case that you are a Customer, P-DICTOR may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause	Purposes	Lawful Basis
1	For consideration and approval on the request for purchase of product and/or using of service including the procedures for identity verification, verification of authority, granting and obtaining of authority, risk assessment for entering into relevant transactions and the proceedings in accordance with relevant internal procedures of P-DICTOR for entering into agreement, the operation under the agreement, product delivery, provision of service including contacting and coordination, collection of expenses and delivery of relevant documents, etc.	Contractual and legitimate interest basis
2	For the benefit in the evaluation, improvement and development of products, the provision of services and relevant sales promotions of P-DICTOR including for surveying satisfaction concerning products and services of P-DICTOR so that they are appropriate and suitable with your requirement.	Legitimate interest basis
3	For using as information and supporting documents for any proceeding with banks, financial institutions, Department of Business Development, Revenue Department, Excise Department, Stock Exchange of Thailand, the Office of Securities and Exchange Commission and other relevant external authorities.	Legitimate interest basis

2.3 In case that you are a Trade Partner, P-DICTOR may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause	Purposes	Lawful Basis
1	For proceedings in accordance with relevant procedures prior to entering into agreement such as: Trade Partner registration; Consideration on qualifications of Trade Partner; Preparation of information before entering into procurement process such as creating median price, specifying names and details of Trade Partners in the internal system of P-DICTOR, etc.; The purchase or acceptance of bidding forms, attending the clarification, the presentation concerning procurement works (as the case may be), price bargaining and announcement of the winning bidder; Invitation to bid, bidding, verification of authority, the granting or obtaining of authority for submission of bidding documents of the bidders and the consideration on qualifications of P-DICTOR’s bidders in accordance with procurement procedures of P-DICTOR including the case that the bidders are the service provider, legal advisor, accounting advisor, business advisor and tax advisor, auditor, financial advisor, financial institution, advisor on accounting and finance system development; Preparation of confidentiality agreement.	Contractual and legitimate interest basis
2	For the necessity in the conducting of transaction between Trade Partner and P-DICTOR, such as: Identity verification, verification of authority, the granting or obtaining of authority including for using as supporting documents for conducting relevant transactions; Proceedings in accordance with rules, regulations and relevant internal procedures of P-DICTOR; Consideration, preparation and execution of commercial agreements; The compliance with hiring agreement, service agreement, other commercial agreements and relevant agreements or cooperation between P-DICTOR and Trade Partners including the procedures for requesting and consideration of relevant documents which may contain personal data of the director of the company which is a third party or representative of state authorities; The acceptance of work pursuant to agreements between P-DICTOR and Trade Partners, the administration of commercial supplies and products, the issuance of work certification until completion.	Contractual and legitimate interest basis
3	For the compliance with relevant laws concerning the conducting of transactions between Trade Partners and P-DICTOR such as the laws concerning procurement of state authorities, laws concerning taxation, laws on the inspection of rights and benefits of the land, laws concerning state audit, laws concerning securities and exchange and laws concerning official information.	Legal obligation basis

2.4 In case that you are a Person Having Business Relationship, P-DICTOR may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause	Purposes	Lawful Basis
1	For business communication such as having business contact, appointment, attendance, conference, meeting and converse in relation to products or services and relevant projects of P-DICTOR or the projects relating to P-DICTOR including the recording of details concerning such contact.	Legitimate interest basis
2	For qualification check or appropriateness evaluation before making a decision to enter into transaction, risk assessment on the entering into relevant transactions, identity identification and verification, verification of authority, the granting or obtaining of authority for the execution of any agreement or contract with P-DICTOR, due diligence investigation on the status of business or other types of profile inspection and proceedings in accordance with relevant internal procedures of P-DICTOR.	Legitimate interest basis
3	For consideration, preparation, execution of relevant contracts or agreements including the administration of such contracts or agreements.	Legitimate interest basis
4	For consideration on the request for participation in the projects of P-DICTOR or the projects in collaboration between P-DICTOR and the third parties or government authorities and the relevant proceedings in relation to such projects.	Legitimate interest basis

2.5 In case that you are an Operator in PTT Group, P-DICTOR may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause	Purposes	Lawful Basis
1	For identity verification as an Operator in PTT Group.	Legitimate interest basis
2	For relevant contacting and coordination in relation to work collaboration between P-DICTOR and group companies including the notification of news and information concerning business operation or activities or projects between companies in PTT Group.	Legitimate interest basis
3	For the compliance with relevant policies of P-DICTOR and PTT Group and for using as information in support of the supervision of group companies, inspecting the operation and compliance with PTT Group way of conduct policy.	Legitimate interest basis
4	For coordination with external authorities in relation to the conduct of business in PTT Group.	Legitimate interest basis
5	For using in order to support the consideration and selection of employees to perform work in P-DICTOR, the consideration on the acceptance of employee transfer as P-DICTOR’s employee. In case that P-DICTOR has accepted an Operator in PTT Group, which is an employee of group companies, to perform work in P-DICTOR in accordance with the criteria specified in the internal regulations and rules of P-DICTOR, P-DICTOR may use your personal data for contacting and coordination, performing duties or conducting any transaction with Customers, Trade Partners, companies in PTT Group, government sectors, state enterprises, state authorities, public organizations, independent organization established under the laws, any other authority or third party, in the capacity of the representative of P-DICTOR, or performing work as assigned by P-DICTOR including the entering into agreements, the amendment to relevant contracts or agreements, the granting or obtaining of authority as well as providing clarification, information or statements to the third parties or participating in trainings, seminars, academic conferences or lectures for the third parties on behalf of P-DICTOR including for supporting the proceedings in accordance with internal procedures of P-DICTOR, performance evaluation or payment of remuneration for work or welfare.	Contractual and legitimate interest basis
6	For authority verification, granting or obtaining of authority including for using as supporting evidence for conducting relevant transactions.	Legitimate interest basis
7	For using as supplemented information of the meeting, joint operation, preparation of information before entering into joint procurement process between companies in PTT Group in accordance with the relevant internal rules, regulations and procedures of P-DICTOR in relation to procurement, preparation of relevant documents in relation to the operation, recording of the meeting and preparation of minutes of the meeting.	Legitimate interest basis
8	For public relations in relation to the proceedings of the project and meeting between P-DICTOR and group companies.	Legitimate interest basis
9	For using as supporting information for the checking of qualification or appropriateness on the performance of contracts or agreements that the companies in PTT Group have provided services for P-DICTOR.	Legitimate interest basis
10	For the provision of services under the contacts or agreements between P-DICTOR and group companies.	Legitimate interest basis
11	For work improvement or the provision of relevant services between P-DICTOR and companies in PTT Group.	Legitimate interest basis

In case that the personal data collected by P-DICTOR for the aforementioned purposes is the data necessary for the performance of agreements or the compliance with relevant applicable laws, if you refuse to provide such necessary personal data, P-DICTOR may not be able to consider entering into transaction or perform administration in accordance with the agreement with you (as the case may be).

Furthermore, in case that you have provided personal data of other person for us, you shall be responsible to inform those people of this Personal Data Privacy Notice and/or the letter requesting for consent (if necessary).

3. Personal Data which shall be collected

In general, for the collection of your personal data, P-DICTOR shall collect your personal data by directly requesting the data from you; nonetheless, there may be some circumstances that P-DICTOR collects your personal data from other sources such as the company that you are positioned in, your employee, secretary or coordinator, government authorities or state authorities or other sources of publicly disclosed information such as website and searchable data on the internet, etc.

In this regard, P-DICTOR shall proceed to collect your personal data as follows:

3.1 General personal data

Identity data such as first name, last name, identification card number, passport number, date of birth, gender, age, nationality, signature, photo, identity number of the professional license, Employee ID (only for the case of an employee of companies in PTT Group), etc.;
Contact data such as address, a copy of house registration, phone number, facsimile number, email, Geolocation, emergency contract person, social media account, LINE ID, secretary information, etc.;
Financial data such as bank account number, etc.;
Communication data with P-DICTOR such as information concerning date, time and place having contact with P-DICTOR, information of the recording of video or voice upon having contact with P-DICTOR, etc.;
Data regarding companies or authorities that you are working in, such as companies or authorities that you are working in, place of work, position of work, etc.;
Data regarding educational profile, work profile, training, proficiency and relevant achievements, etc.;
Data regarding personal preferences and interest;
Recording of videos by closed-circuit television (CCTV);
Data on the participation of meetings between P-DICTOR and group companies including data on the participation of trainings, seminars, activities or other projects held by P-DICTOR as there may be the recording of photo, video or voice during such meetings, trainings, seminars or activities;
Other necessary data for the legal proceeding or legal execution such as marriage status and data concerning assets, etc.;
Opinions, recommendations and complaints;
Records on the participation of relevant activities or projects with P-DICTOR;
Screening data pursuant to communicable disease prevention measures;
Data concerning the utilization of relevant information systems of P-DICTOR including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.;
Other personal data for the provision of facilitations as necessary such as the preferred food or beverage, etc.

3.2 Sensitive personal data

In general, P-DICTOR has no intention to collect and use religious and blood type data specified in your identification card for any specific purpose. In the event that you provided P-DICTOR the copy of your identification card, it is requested that you conceal such data. If you did not conceal such data, it shall be deemed that you authorized P-DICTOR to conceal those data and it shall be deemed that such document with concealed data be valid and legally enforceable in all respects. In case that P-DICTOR is unable to conceal those data due to some technical limitation, P-DICTOR shall collect and use such data as a part of your identification documents only.

In case that it is necessary for P-DICTOR to collect your sensitive personal data, unless otherwise prescribed by laws, P-DICTOR shall request for your express consent on case-by-case basis

In this regard, there might be the Processing of the following sensitive personal data by P-DICTOR :

Religious data;
Data concerning health and/or disability;

4. Period for retention of personal data

P-DICTOR shall retain your personal data for the period necessary for the purposes of the collection, use or disclosure of personal data set out in this Privacy Notice. The criteria for determination of retention period are the period necessary for P-DICTOR to utilize your personal data in accordance with the purposes and it shall be further retained pursuant to the period necessary for the compliance with laws or the statutory prescription period, or for the establishment, compliance, exercise or defense of legal claim, or for other reasons pursuant to the internal policies and rules in the organization of P-DICTOR.

5. Disclosure of personal data

In order to carry out the proceedings for the purposes set out in this Privacy Notice, P-DICTOR may disclose your personal data to the third parties as follows:

Companies in PTT Group;
The government authorities, independent organizations established under the laws or other authorities as prescribed by laws including the officers which exercise powers or perform duties under the laws such as court, polices, Revenue Department, Anti-Money Laundering Office, Department of Labour Skill Development, Welfare and Labour Protection Department, Office of the Attorney General, the Office of National Anti-Corruption Commission, National Science and Technology Development Agency, etc.;
Authorities, organizations, or the person relating to the exercise of right of claim, the commencing of legal proceeding, the objection to the complaint or the allegation, the defending of the case of P-DICTOR such as the parties of the case and witnesses, etc.;
Agents, contractors/sub-contractors and/or service providers for any operation provided for P-DICTOR such as professional advisors, transportation service providers, the service firms for the conducting of marketing activities, travel and accommodation agencies, the organizer companies for the convening of activities, trainings or seminars, activity organizers, media producers and advertising firms, insurers, auditors and legal advisors, etc.;
Persons Having Business Relationship (in case that it is necessary for the compliance with agreements in case that there is a joint operation of project or business);
Management system standards certification institutes;
Training participants;
Shareholders, debenture holders and the representatives of such persons;
Banks or financial institutions;
The transferee who received the assignment of any right, duty and benefit from P-DICTOR including the person assigned by such transferee to proceed on its behalf such as the case of the restructuring, merger and acquisition, separation or transfer of business, etc.;
Other third parties such as the disclosure of information in the announcement of relevant persons who have been selected through social media channels of P-DICTOR or the public relations of activity photos or news and information on the conducting of activities or projects of P-DICTOR to the mass media and third parties, etc.

6. The submission or transfer of personal data to foreign countries

In some circumstance, we may be required to disclose your personal data to foreign countries, which may have standards of personal data protection different than those of Thailand because P-DICTOR has business operation or the conducting of relevant transactions with companies in foreign countries; therefore, we may be required to disclose your personal data to those companies including government authorities, professional advisors and the related persons having necessity to access to such personal data in the normal course of our business operation. Also, there might be the disclosure of information to foreign countries for supporting the commencement of legal proceedings or arbitrations which may be occurred in the future. Furthermore, P-DICTOR may store your data on computer server or in the cloud of offshore service providers and there might be the processing of data by using programs or applications of the offshore service providers.

In this regard, for the submission or transfer of your data to foreign countries in whatsoever case, P-DICTOR shall comply with the Personal Data Protection Act B.E 2562 (2019).

7. Your rights as the owner of personal data

As the owner of personal data, you have the rights as prescribed in the Personal Data Protection Act B.E 2562 (2019). In this respect, you can request to exercise your relevant rights through the channels specified by P-DICTOR in Clause 9 or through P-DICTOR website, whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to P-DICTOR. In this respect, your relevant rights shall have details as follows:

7.1 Right to withdraw consent

In case that P-DICTOR requests for your consent, you shall have the right to withdraw the consent for the Processing of your personal data that has already given to P-DICTOR unless such withdrawal of consent is restricted by laws or by the agreement that provides you the benefits.

Such withdrawal of consent shall not affect the Processing of personal data legally conducted according to your prior consent.

7.2 Right to access to personal data

You have the right to request for an access to and the request for the copy of your personal data under control of P-DICTOR, including to request P-DICTOR to disclose the acquisition of such data that you have not given consent to P-DICTOR.

7.3 Right to request for the submission or the transfer of personal data

You have the right to request P-DICTOR to transfer your personal data that you have given to P-DICTOR as prescribed by laws.

7.4 Right to object the collection, use or disclosure of personal data

You have the right to object the Processing of data relating to you in respect of the collection, use or disclosure of your personal data as prescribed by laws.

7.5 Right to request for the erasure of personal data

You have the right to request P-DICTOR to delete your personal data as prescribed by laws. Nevertheless, P-DICTOR may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, P-DICTOR shall destroy or cause such data to be unable to identify your identity.

7.6 Right to request the restriction of the use of personal data

You have the right to request P-DICTOR to restrict the use of your personal data as prescribed by laws.

7.7 Right to request for the rectification of personal data

If you found that the data controlled by P-DICTOR is incorrect or you have changed your personal data, you have the right to request P-DICTOR to correct your personal data so that such personal data be accurate, current, complete and not causing misunderstanding.

7.8 Right to lodge a complaint

You have the right to lodge a complaint with the competent officers under the Personal Data Protection Act B.E 2562 (2019) in case that P-DICTOR breaches or does not comply with such Act.

8. Amendment of this Privacy Notice

We may amend and update this Privacy Notice from time to time, and if there is such amendment, we will keep you posted through P-DICTOR website and/or inform you via email. If it is necessary to request for your consent, we will proceed to request additional consent from you.

9. Contact channels

If you have question or require further details concerning the protection of your personal data, the collection, use and disclosure of your personal data, the exercising of your rights or if you have any complaint, you can contact P-DICTOR as per the following channels:

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P-DICTOR Company Limited

Office Address : 555/3 ,Energy Complex, Building C, 5 Floor, Vibhavadi Rangsit Road, Chatuchak, Chatuchak, Bangkok, Thailand 10900.