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CCTV PRIVACY NOTICE
EASY BUY PUBLIC COMPANY LIMITED
[Latest updated: June 6th, 2023]
1. Purpose and Scope
- EASY BUY Public Company Limited (hereinafter referred to as "the Company" or “we”) recognizes the importance of the personal information you have entrusted to us, and we will comply with the Personal Data Protection Act B.E. 2562 to ensure the individual right to be protected regarding the collection, use, storage, disclosure, and deletion (hereinafter referred to as "processing") of personal data in order to protect life, health, and property in accordance with security measures.
- Through the use of CCTV devices, the company collects personal data of all staffs, contractors, workers, visitors, customers, or other individuals (hereinafter referred to as "you" or "your") who enter the monitored space within our buildings and facilities (hereinafter referred to as "Area").
Why we collect, use and/or disclose personal data
- - To prevent, protect, and/or suppress a danger to a person's life, body, and health, as well as personal safety, including your property;
- For the protection of buildings, facilities, and property against damage, obstruction, destruction, and other crimes;
- To facilitate authorities in enforcing the law in the areas of suppression, prevention, investigation, and litigation;
- To assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
- To assist in the investigation or proceedings concerning a whistleblowing complaint;
- To support the processing restriction due to legal reasons including but not limited to civil case or labor case
- To verify a person's identification and to comply with applicable laws;
- To inspect the employee's performance in accordance with the company's internal policies and procedures.
Legal basis (Legitimate grounds)
“Legal basis” refer to the necessity grounds for processing personal data in accordance with Section24 and 26 of The Personal Data Protection Act B.E.2562. The following legal basis are used by the company to process your personal data:
- - Legitimate Interest: The company processes your personal data for the safety and security of all staffs, contractors, workers, visitors, customers, or other individuals who enter our monitor space, as well as for the safety and security of our premises and assets so that unrelated individuals are unable to enter restricted areas, as well as for the investigation of any incidents that occur within our areas and to inspect the employee's performance in accordance with the company's internal policy.
- Legal Obligation: The company may process your personal data to comply with our legal obligations, to support or assist government organizations at their request, and to process as evidence in the event of a crime or an accident that occurs within or around our monitoring area.
Data Controller Contact Information |
Data Protection Officer (DPO) Contact Information |
|---|---|
EASY BUY Public Company Limited |
Email : contactpdpa-dpo@easybuy.co.th |
2. Personal data collected
- The following are the personal data which the company processes:
- Identifiable information: portrait, record video for example.
- IT information: location, for example
- Property information: a company asset, an employee's belongings, or your own property shown on CCTV footage, for example.
3. How the Company Collect Your Personal Data
- The Company collects personal data directly through the use of CCTV devices.
4. How the Company Process Your Personal Data
- The Company is processing personal data for the objective of monitoring within or around our areas related to EASY BUY business, on the legitimate grounds under The Personal Data Protection Act B.E.2562.
- The Company will process your personal data in accordance with the informed objective, which includes any other objective that is related to the informed objective and does not contradict or go far beyond scope. If we need to process your personal data for an objective that is not related to the informed objective, we will notify you via this CCTV Privacy Policy of the additional objective and legitimate ground for processing your personal data.
5. Usage of Personal Data with Third-Party Organizations
- In order to achieve the objective set forth in this Policy, the company may be required to disclose your Personal Data to the following parties: governmental and/or regulatory organizations with the authority to request your personal data, such as the Royal Thai Police, Attorney General's Office, Court, as well as authorities with the power to request your personal data, such as the Inquiry Official or prosecutor with regard to the investigation and prosecution.
- For the case where personal data is being passed on the external third-party organizations, Easy Buy will ensure that the minimum amount of personal data is being sent and consider anonymization and psuedonnymization techniques for greater security. Nevertheless, external third-party organizations who will process personnel’s personal data for Easy Buy will be required to have an appropriate privacy policy. Easy Buy does not permit these external third-party organizations to use the personnel’s personal data in a way that diverge from the agreed scope and purpose.
6. Transferring of Personal Data to Foreign Countries
- The Company does not cross-border transfer the personal data collected by CCTV.
7. Security Measures for Personal Data Protection
- The company has established a Customer Privacy Policy, which has been widely publicized within the company, as well as a guideline and policy to ensure the security of personal data collection, use, and disclosure by maintaining confidentiality, integrity, and availability of personal data, and the company shall have arranged to review such Policy, as well as this Policy, in a reasonable timeframe.
8. Period for Retention of Personal Data Storage
- The company will only retain your Personal Data for as long as it is reasonably necessary to carry out our duties to achieve the CCTV Monitoring objective outlined in this Policy or to carry out our obligations in connection with a judicial/legal action, or until the following term has expired:
Location |
Locations where CCTV cameras are installed |
Retention Period |
|---|---|---|
1. MUANG THAI PHATRA COMPLEX |
252/246 4 th floor Ratchadapisek Road, Huai Khwang, |
1 year |
2. RASA TWO |
1818, 8-11 th floor, Petchburi Road, Makkasan, |
2 months |
3. Umay+ branches nationwide, Operations Center, |
https://www.umayplus.com/contact/branchlocations |
2 months |
- After the above-mentioned retention period has expired, the footage will be automatically deleted from the system, or the company will delete or make personal data non-identifiable.
9. Data Subject Rights
- Your personal data rights include:
- - Right of Access – you have the right to request a copy of all your personal data and assess if the company is processing your personal data in accordance with the law or not
- Right to Data Portability – for the case where a company has an automated platform allowing you to access your personal data automatically:
o You have the right to ask for your personal data to be transferred automatically to other organizations
o You have the right to ask for your personal data to be directly transferred to other organization, with the exceptions of cases where there is a technological limitation
- Right to Object – you have the right to object to any data process activity of your personal data for the legal bases, including: - o Public Task or Legitimate Interest
- o Direct Marketing Purposes
- o Scientific, historical or statistic research purposes, unless the processing is necessary for public task;
- - Right to Erasure – you have the right to request data deletion or anonymization, in accordance to the following cases:
- o Expiration of data processing required terms
- o Consent has been withheld
- o Objections raised on the data processing activity
- o The processing activity is not in accordance with the law
- - Right to restrict processing – you have the rights to restrict any data processing activities, in accordance with the following cases:
- o During the process of personal data assessment as requested
- o For cases related to personal data which has initially asked for deletion and erasure but was followed by an additional request of processing restriction instead
- o For cases when the data processing terms have passed, but you have requested for processing restriction due to legal reasons
- o During the process of personal data processing objection verification
- - Right to Rectification – You have the right to edit your personal data to be correct and concurrent to the present. If any mistake was detected, the company might not edit this themselves.
In some cases, according to the nature of the operation, the Company may not be able to perform the action as you request, for example, it is necessary to perform the obligations under the contract or the law, etc.
Please acknowledge that the company will keep records of the transactions that have been processed in connection with your request for use in resolving any problems that arise.
In the case where you have the intention to exercise your personal data protection rights, or to file complaint against your personal data processing, please contact company’s DPO (contact details have been provided above).
The Company will advise and process this request in a secure and timely manner.
10. Notice Revision
- This Privacy Notice was late updated on June 6th, 2023. The Company holds the rights to review and edit this notice as the Company see appropriate.
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