Privacy notice

Privacy Notice for Shareholder

P-DICTOR Company Limited (hereinafter called “P-DICTOR” or “We”, “we”) giving highest precedence to protect the personal data of our shareholders or our debenture holders and also in a circumstance you are the power of attorney (hereinafter called “agent”) from aforesaid shareholders or debenture holders. In order to enhance the confident that we will protect and manage your personal data in accordance with the Personal Data Protection Act B.E 2562(“PDPA”) then we establishing this Privacy Notice for your acknowledgement of the details of the processing of personal collecting, use and disclosure (shall collectively called “the processing”) that may be arising and including to inform you of the rights of your personal data and the contacting us channels.

1. Purposes of Collecting, Use and Disclosure of Personal Data

P-DICTOR may collect, use or disclose your personal data under the lawful basis for the various purpose as follows;

Clause	Purposes	Lawful Basis
1	For management of shareholders and debenture holders registration including for issuance of proxy by shareholders and debenture holders as well as other relevant activities pursuant to public company law and securities and exchange law and or other relevant laws.	Legal Obligation Basis
2	For payment of dividend to shareholders or for repayment the face value and or interest to debenture holders	Legal Obligation Basis & Contractual Basis
3	For the subscription for accessing and using any website or application providing by P-DICTOR to debenture holders such as P-DICTOR Debenture Cyberplus website and for using such website or application under the prescribed using conditions.	Contractual Basis
4	For holding the general meeting and the attendees register of shareholders or debenture holders including the related organizing of such meetings for example; to register the attendees of the meetings, to record the resolution of the meetings for instance.	Legitimate Interests
5	For recording of images, audio and video recordings during the meetings for the benefit of broadcasting the meeting via P-DICTOR website and through other P-DICTOR communication channels or to facilitate the attendees of the meetings to rerun in after or for the public relation of P-DICTOR or for other benefit of the attendees of the meetings	Legitimate Interests
6	For recording the meeting and to arrange the minute of meeting for submission to the relevant authorities such as the Stock Exchange of Thailand, P-DICTOR Legal Consultant, shareholders, debenture holders, and to publicize via P-DICTOR website and other communication channels.	Legitimate Interests
7	For issuing the newsletter regarding any investor relation activities arranged for shareholders and debenture holders as P-DICTOR deem appropriate and for using as procedure for selecting the eligible participants.	Legitimate Interests
8	For analyzing any information for the preparation of activities, to organize the event, to facilitate shareholders and debenture holders who attending the activities arranged by and deem appropriated by P-DICTOR such as the preparation of venue, the preparation of food and beverage or preparation of transportation or keepsake for instance.	Legitimate Interests
9	For arranging of insurance policy or travel insurance policy (if needed) in the event you participating in any activities organized by P-DICTOR.	Legitimate Interests
10	For being the data base and for any management regarding to provide any right and benefit to you as P-DICTOR shareholders or debenture holders such as the right for subscription for the IPO shares of companies under PTT Group, right for subscription for debenture or to provide the discount for health check at named hospitals.	Legitimate Interests
11	For being the data base for P-DICTOR’s stakeholders and or for being the information for the relationship administering and for any coordination with P-DICTOR concerned parties including for opinion survey for analysis and improvement of P-DICTOR’s operation.	Legitimate Interests
12	For risk management and internal control, monitoring supervisory including internal audit of Internal Audit Office, good corporate governance and for internal organization management.	Legitimate Interests
13	For establishing the right to legal claim, for compliance with or exercise any legal claim or for raising any defense against any legal claim, for proceeding any litigation and including for execution of the judgement	Legitimate Interests
14	For compliance with legal obligations, orders of the competent and legally authorities or any competent official such as to comply with summon, court injunction, police officers, prosecutors, government authorities and for reporting or disclosure any information to government bodies or independence entities.	Legal Obligation

Personal data collected by P-DICTOR for the purposes of payment of dividend to shareholders, payment of face value and or interest to debenture holder, administering of shareholders registration or debenture holders and including proxy are necessary for P-DICTOR to comply with the contractual obligation and under the right and obligation of the issuance of debenture and with the debenture holders, to comply with the applicable law as well as to comply with the public limited company law, to comply with securities and exchange law. If you do not provide P-DICTOR such necessary personal data, P-DICTOR may unable to manage and administer the shareholder or debenture holder agreement between you and P-DICTOR including any benefit (if any) of shareholders or debenture holders

2. Personal Data that collected

In general P-DICTOR shall collect your personal data by request directly from you for example by have you to fill in any formats determined by P-DICTOR or enquiring data from you or request you to submit any document already containing your personal data. However, there may be any some circumstance that P-DICTOR collect your personal data from other sources in order to fulfil the aforesaid purposes such as from the securities registrar.

The categories of personal data collected by P-DICTOR are follows;

2.1 General Personal Data

Data used for Identifying you (Identity Data) such as first name, last name, identity card number, passport number, date of birth, gender, age, nationality, signature, information regarding to changing of first name and or last name, current photo.
Your contact detail (Contact Data) such as address, phone number, email
Financial information (Financial Data) such as bank account number (used for receiving dividend payment, face value and or interest), your number of share or debenture held.
Data regarding to the communication with P-DICTOR (Communication Data) such as video and audio recording when you contact P-DICTOR
Data regarding to any activity participated with P-DICTOR such as image recording or video recording
Data regarding to any use of electronic account such as user name of Line ID
Other data such as occupation, opinions or recommendations.

2.2 Personal Data that sensitive

In general, P-DICTOR do not require to collect any religion and blood type specified in your identity card, for any specific purpose. In the event that you provide P-DICTOR the copy of your identity card, you are requested to make invisible such data. If you do not make invisible of such data, it will be deemed that you already authorized P-DICTOR to make invisible those data and such document shall be deemed valid and legally binding in all aspects. In case P-DICTOR is unable to make invisible of those data as limited by some technical issue, P-DICTOR shall collect and use such data as being part of your identification documentation only.

However, for the personal data processing of shareholders and debenture holders of P-DICTOR, there may be some activities that P-DICTOR shall request some additional sensitive personal data when you participate in any activities for shareholders and debenture holders. P-DICTOR may request for sensitive data for example the data regarding to your health for instance in order to facilitate you related to such activity or for other purpose which we will specifically notify in the request consent form and P-DICTOR shall clearly request your consent before collecting such sensitive personal data.

3. Retention Period of Personal Data

P-DICTOR shall retain your personal data as long as it is necessary for the purposes of collecting, use or disclosure such personal data set out in this Privacy Notice. The criteria for establishing the retention period are the duration of relationship between P-DICTOR and you, the ongoing duration of any interest P-DICTOR still providing to you, further retaining your personal data as necessary period in order to comply with applicable law or within legal prescription for establishing of right to legal claim, to comply with or to exercise the right to legal claim or to raise against any right to legal claim for other courses as specified in Policy and Internal Rules and Regulation of P-DICTOR.

4. Disclosure of Personal Data

In order to comply with the purposes, set out in this Privacy Notice, P-DICTOR may disclose your personal data to outsiders as determined below;

subsidiary companies, affiliated companies and PTT Group companies for their supporting for the achievement of the aforesaid purposes set out
government authorities, regulator authorities or other authorities as prescribed by law including the competent officers utilizing power under any applicable laws such as court, police, the Securities and Exchange Commission, revenue department
Agencies, contractors, subcontractors, and/ or other service providers providing any operation of P-DICTOR for example, the organizers for operating any activities and to facilitate shareholders, debenture holders, auditors, lawyers, legal consultant, financial institutes appointed as financial advisor or debenture underwriter
Insurance companies and or insurance brokers, life insurance brokers providing any insurance of travelling insurance to shareholders or debenture holders or their agents in case those insurance are provided as of your participating in any activities arranged by P-DICTOR
Banks responsible for any payment to shareholders or debenture holders
Registrar of shareholders and debenture holders
Debenture Holders Representative
Hospital or clinic.

5. Submit or transfer Personal Data to abroad

P-DICTOR may install your personal data on computer servers or in cloud of the service providers situated in abroad and there may be the personal data processing by using software package of program or application of service providers in abroad.

In any circumstance, the submission or transferring any personal data to abroad, P-DICTOR shall comply with the Personal Data Protection Act B.E 2562.

6. Your rights as owner of Personal Data

As the owner of personal data, you have legal right as prescribed in the Personal Data Protection Act B.E 2562. You can exercise your rights in accordance with terms specified under Clause 8. Of this Privacy Notice or via P-DICTOR website. You will be able to exercise any right when the Personal Data Protection Act B.E 2562. Come to enforce with P-DICTOR Your rights are as follows;

6.1 Right to Withdraw Consent

In the event P-DICTOR requested your consent, you will have the right to withdraw such consent for the processing of your personal data already given to P-DICTOR unless such withdrawal restricted by law or by any contract that benefit you

Such consent withdrawal shall not affect any personal data processing legally conducted according to your prior consent.

6.2 Right to Access to Personal Data

You have the right to request to access to your personal data, to request for making copy which is under controlled by P-DICTOR including to request P-DICTOR to disclose the source of data gained that you not giving consent to P-DICTOR of such data.

6.3 Right to request for submitting or transferring your Personal Data (Data Portability Right)

You have the right to request P-DICTOR to transfer your given P-DICTOR personal data to other party as prescribed by law.

6.4 Right to Object the Collect, Use or Disclosure of Personal Data (Right to Object)

You have the right to object the data processing relating to you on collecting, use or disclosure personal data as prescribed by law.

6.5 Right to Request to Delete Personal Data (Erasure Right)

You have the right to request P-DICTOR to delete your personal data as prescribed by law. Nevertheless, in the event that P-DICTOR installed your personal data by using electronic system which some system may unable to delete your personal data and in such circumstance, P-DICTOR shall destroy such personal data or make such personal data to be unidentified personal data.

6.6 Right to Request to Restrict of Processing Personal Data (Right to Restrict Processing)

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

6.7 Right to Request the Personal Data to be Rectified (Rectification Right)

In the event you finding that any data controlled by P-DICTOR is incorrect, you have the right to request P-DICTOR to correct your personal data so that such personal data shall be accurately, currently, completely and shall not lead to any misunderstand.

6.8 Right to Lodge Complaint

You have the right to file the complaint with the competent authority under the Personal Data Protection Act B.E 2562 if P-DICTOR breach or not compliance with the said Act.

In the event that the owner of personal data filing such complaint under Personal Data Protection Act B.E 2562 and once P-DICTOR receives such complaint; we will comply within the period stipulated by law. However, P-DICTOR reserves the right to decline or not comply to such complaint if there is any legal prescribed.

7. Amendment of this Privacy Notice

We may amend and update this Privacy Notice from time to time. We will publish such amendment (if any) via P-DICTOR website. and or inform you in the general meeting invitation letter and or through the Stock Exchange of Thailand newsletter channel and or via email. In the event that it is necessary to receive your consent, we will also request for such consent too.

8. Contacting Channel

If you have any inquiries or need more detail related to the protection of your personal data collected, used or disclosed your personal data, your rights exercising or you may have any complaint, you can contact P-DICTOR as follows;

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P-DICTOR Company Limited

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