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Privacy Notice

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For customers, business partners and someone with business relationships

Sangrompo Autopart Co., Ltd. (hereinafter referred to as the “Company”) places great importance on the protection of personal data of its customers, business partners and someone with business relationships (collectively referred to as “you”) and to assure you that the Company will protect and treat your personal data in accordance with the Personal Data Protection Act. The Company has therefore prepared this Privacy Notice to inform all relevant persons of the details of the processing of personal data, whether it is collection, use and/or disclosure (collectively referred to as “processing”) that may occur, as well as to inform you of your rights regarding your personal data and the Company’s contact channels.

1. Types of persons whose personal data the Company collects

Under this Privacy Notice, the Company collects the following personal data of individuals:

  • 1.1 Customer Refers to a person who hires and/or receives services from the Company, or other persons who contact to inquire about information or services of the Company, persons who receive service information through various media, and includes natural persons who are related to or are representatives of juristic persons who are customers, such as executives, directors, operators, employees, agents, representatives, or any other natural persons, and persons whose personal data appears in various documents related to transactions between the Company and that juristic person, such as coordinators, purchasers, recipients of goods, check issuers, etc., including persons who have provided data to the Company by that juristic person.
  • 1.2 Business partner Refers to a person who will sell or sell products and/or services to the Company, regardless of whether or not they are registered as a business partner with the Company, such as a contract partner, service provider, consultant, etc., and includes natural persons who are related to or are representatives of a juristic persons who are business partners, such as an executives, directors, operators, employees, agents, representatives, or any other natural persons, and persons whose personal data appears in various documents related to transactions between the Company and that juristic person, such as coordinators, shippers, check issuers, etc., including persons who have provided data to the Company by that juristic person.
  • 1.3 Someone with business relationship Refers to other persons other than customers or business partners who have a relationship related to business operations, such as visitors, and includes natural persons who are related to or are representatives of that juristic person, such as executives, directors, operators, employees, agents, representatives, or any other natural persons, and persons whose personal data appears in various documents related to transactions between the company and that juristic person.

2. Purpose of collecting, using or disclosing personal data

  • 2.1 In general, whether you are a customer, business partner or someone with a business relationship The Company may process your data for the following purposes:
    No. Purpose Legal basis
    1 For coordination related to the company's business operations Necessity for legitimate interests
    2 To collect and use your personal data, including name-surname, position, department, photos-videos related to the Company's operations and activities for public relations through various channels, such as internal company email, the Company's website, or other media such as publications, etc. Necessity for legitimate interests
    3 To carry out business planning, reporting and forecasting, risk management, supervision, auditing and internal management of the Company, including for use in internal operations related to disbursement of funds of the Company's financial accounting unit. Necessity for legitimate interests
    4 For the purpose of carrying out any action relating to the transfer of rights, duties and benefits, such as making contracts between each other or which have been done in accordance with the law. Necessity for legitimate interests
    5 To be a database of the Company's stakeholders and/or use the data for relationship management or coordination of various matters related to the Company, including surveys to analyze and improve the Company's operations. Necessity for legitimate interests
    6 To disclose data necessary for compliance with the various assessment criteria in which the Company participates. Necessity for legitimate interests
    7 For the investigation of complaints within the company, prevention of corruption or any other legal proceedings, including the examination and management of complaints and allegations related to the operations of the company or related persons to ensure transparency and fairness for all parties. Necessity for legitimate interests
    8 To consider joining the company's projects or activities, such as study tours, business visits, seminars, training projects, or other projects of the company or that the company conducts in collaboration with external parties or government agencies, etc. Necessity for legitimate interests
    9 For security within the building and premises, recording images of people who come into contact with the company via CCTV. Necessity for legitimate interests
    10 For the establishment of legal claims, granting power of attorney and receiving power of attorney, the performance or exercise of legal claims, or the defense of legal claims, the taking of legal actions, and the enforcement of legal actions. Necessity for legitimate interests, legal obligation
    11 For compliance with the law or compliance with court orders, letters or orders of agencies, independent organizations or officials who have duties and authority under the law, such as compliance with subpoenas, seizure orders, court orders, police officers, prosecutors, government agencies, including reporting or disclosing data to shareholders, government agencies or independent organizations such as the Revenue Department, the Office of the Auditor General, the National Anti-Corruption Commission, etc., in order to comply with relevant laws. Legal Obligation
    12 To comply with laws regarding public health benefits, such as health protection from dangerous communicable diseases or epidemics that may be transmitted or spread into the Kingdom. Legal Obligation
    In addition to the above purposes, the Company may further process your personal data in the following cases:
  • 2.2 In case you are a customer The Company may process your data for the following additional purposes:
    No. Purpose Legal basis
    1 For consideration of approval of requests for products and/or services, including identity verification processes, authority verification, granting power of attorney and receiving power of attorney, consideration of risks in conducting related transactions, and conducting operations in accordance with the Company's internal processes for contracting, performing contracts, providing services, including contact and coordination, collecting expenses, delivering related documents, etc. Contractual Basis

    Necessity for legitimate interests
    2 For the purpose of evaluating, improving and developing the service, including surveying satisfaction regarding the company's service in order to make it appropriate and meet your needs. Necessity for legitimate interests
    3 To be used as data and supporting documents for any operations with banks, financial institutions, the Department of Business Development, the Revenue Department, the Excise Department, and other relevant external agencies. Necessity for legitimate interests
  • 2.3 In case you are a business partner The Company may process your data for the following additional purposes:
    No. Purpose Legal basis
    1 To carry out various processes before entering into a contract, such as:
    • Partner Registration
    • Consideration of partner qualifications
    • Preparing data before entering the procurement process, such as investigating and preparing the median price, specifying the name and details of the business partner in the company's internal system, etc.
    • Purchasing or receiving an auction form, attending an explanation, presenting work related to the procurement work (as applicable), negotiating prices, announcing the winner.
    • Invitation to bid, bid submission, verification of authority, granting power of attorney and receiving power of attorney to submit bidding documents by bidders, and consideration of the qualifications of bidders to the Company in accordance with the Company's procurement process, including cases where the bidder is a service provider, legal advisor, business advisor, auditor, financial advisor, financial institution, etc.
    • Preparing a Confidentiality Agreement
    Contractual Basis

    Necessity for legitimate interests
    2 For the necessity of conducting transactions between business partners and the company, such as:
    • Verification of identity, verification of authority, granting power of attorney and receiving power of attorney, including use as evidence for related transactions.
    • Compliance with the Company's internal rules, regulations and processes.
    • Consideration, preparation and signing of commercial contracts.
    • Compliance with employment contracts, service contracts, other commercial contracts and related agreements or cooperation between the Company and its contracting parties, including the process for requesting and considering related documents that may contain personal data of the Company's directors who are external persons or representatives of government agencies.
    • Acceptance of work according to the contract between the company and the business partner until completion
    Contractual Basis

    Necessity for legitimate interests
    3 To comply with laws related to transactions between business partners and the Company, such as tax laws, etc. Legal Obligation
  • 2.4 In case you are someone with a business relationship The Company may process your data for the following additional purposes:
    No. Purpose Legal basis
    1 For business communication, such as contacting, making appointments, meeting, holding meetings, participating in business discussions, including recording details of such contacts. Necessity for legitimate interests
    2 For the purpose of checking qualifications or assessing suitability before deciding to enter into a transaction, considering the risks of entering into a related transaction, verifying and confirming identity and/or checking authority, granting power of attorney and receiving power of attorney to sign any agreement or contract with the Company, examining business status or other forms of background checks, and conducting various internal processes of the Company. Necessity for legitimate interests
    3 For consideration, preparation, signing of contracts or related agreements, including the management of such contracts or agreements. Necessity for legitimate interests

    In the event that the personal data collected by the Company for the above purposes is necessary for the performance of a contract or compliance with applicable laws. If you do not provide such required personal data, the Company may not be able to consider entering into a transaction or manage the contract with you (as the case may be).

    In addition, in the event that you provide the Company with data about another person. You are responsible for informing those individuals of this Privacy Notice and/or obtaining their consent, if required.

3. Personal data collected

In general, when collecting your personal data, the Company will collect personal data by requesting or inquiring about that data directly from you. However, in some cases, the Company may collect your data from other sources, such as your employer, employees or coordinators on your behalf, government agencies or state agencies, or other publicly available sources, such as websites, information searchable on the Internet, etc. The Company collects your personal data as follows:

  • 3.1 General personal data
    • (1) Identification data such as name, surname, national ID card number, passport number, date of birth, gender, age, nationality, signature, photograph, driver's license information, etc.
    • (2) Contact data such as address, house registration copy, telephone number, fax number, email, emergency contact person, etc.
    • (3) Financial data such as bank account numbers, etc.
    • (4) Data about the company or organization where you work, such as the company you work for or the parent organization, your workplace, job position, etc.
    • (5) Data about educational history, work history, training, expertise, and achievements, etc.
    • (6) CCTV camera recording
    • (7) Data on participation in meetings between companies, including information on participation in trainings, seminars, activities or other projects organized by the company, which may include still images, motion pictures and/or audio recordings during such meetings, trainings, seminars or activities.
    • (8) Other necessary data for background checks, suitability assessments or risk considerations prior to making a decision to enter into a transaction, including for legal proceedings or enforcement, such as marital status, property information, etc.
    • (9) Comments, suggestions, complaints
    • (10) Screening data according to epidemic prevention measures
  • 3.2 Sensitive data

    In general, the Company does not intend to collect and use the religious data and blood type that appear on your ID card copy for any specific purpose. If you have provided a copy of your identification card to the company. Please conceal such data. If you have not concealed the above information. It is considered that you have allowed the company to conceal such data and that the documents with such data concealed are considered valid and enforceable according to the law in all respects. However, if the Company cannot conceal the data due to certain technical limitations, the Company will collect and use such data only as part of your identity verification documents.

    In case that the Company is required to collect your sensitive data. The Company will request your express consent on a case-by-case basis, unless otherwise required by law.

    The Company may process sensitive data as follows:

    • (1) Religious data
    • (2) Data about health and/or disability

4. Period of collection of personal data

The Company will retain your personal data for as long as necessary for the purposes for which the personal data was collected, used or disclosed as described in this Privacy Notice. The criteria used to determine the retention period include the period for which the Company still needs to utilize your personal data in accordance with the purposes, and may continue to retain it for the period necessary to comply with the law or the statutory limitation period, for the establishment of legal claims, the exercise or defense of legal claims, or for other reasons in accordance with the Company's internal policies and requirements.

  • 4.1 In the event that you are a customer, the Company will retain your personal data for a period not exceeding 3 years from the date on which the legal relationship between the customer and the Company ends.
  • 4.2 In the event that you are a business partner, the Company will retain your personal data for a period not exceeding 5 years from the date on which the legal relationship between the business partner and the Company ends.
  • 4.3 In the event that you have a business relationship, the Company will retain your personal data for a period not exceeding 5 years until the document expires or there is a significant change.

5. Disclosure of data

In carrying out the purposes set out in this Privacy Notice, the Company may disclose your data to the following third parties:

  • 5.1 Government agencies, regulatory agencies, state enterprises, government agencies, public organizations, independent organizations established by law, or other agencies as specified by law, including officials who exercise power or perform duties in accordance with the law, such as the court, police, Revenue Department, Department of Skill Development, Department of Labor Protection and Welfare, Department of Energy Business, Ministry of Natural Resources and Environment, Ministry of Transport, Ministry of Energy, Department of Legal Execution, Office of the Attorney General, Office of the Auditor General, National Anti-Corruption Commission, etc.
  • 5.2 Agencies, organizations or individuals involved in the exercise of rights to claim, litigation, dispute of complaints or allegations, or defense of a lawsuit, such as parties to a lawsuit, witnesses, etc.
  • 5.3 Agents, supplier/contractors/subcontractors and/or service providers for any operations for the Company, such as professional consultants, accommodation and travel agencies, event organizing companies, training or seminar organizers, event organizers, media production contractors, public relations contractors, insurers, auditors, legal consultants, etc.
  • 5.4 Business relationships (In case of necessity for the performance of the contract, in case of joint project or business operation)
  • 5.5 Management system certification institute
  • 5.6 Training participants
  • 5.7 Bank or financial institution
  • 5.8 Other external persons, such as public relations of activity images or news of activities or projects to the media and external persons, etc.
  • 5.9 Hospital or medical facility

6. Your rights as a data subject

As a data subject, you have the rights as specified in the Personal Data Protection Act B.E. 2562. You may exercise your rights through the channels specified by the Company in Section 9. Your rights are detailed as follows:

  • 6.1 Right to Withdraw Consent
    In the event that the Company requests your consent, you have the right to withdraw your consent to the processing of your personal data that you have given to the Company, unless the withdrawal of consent is restricted by law or a contract that benefits you. However, the withdrawal of consent will not affect the lawful processing of your personal data that you have already given your consent to.
  • 6.2 Right to Access
    You have the right to request access to and a copy of the data about you held by the Company, including the disclosure of the source of such data that you have not consented to.
  • 6.3 Data Portability Right
    You have the right to request that the Company transfer your personal data that you have provided to the Company as required by law.
  • 6.4 Right to Object
    You have the right to object to the processing of personal data about you where the collection, use or disclosure of personal data about you is required by law.
  • 6.5 Erasure Right
    You have the right to request that the Company erase your personal data as required by law. However, the Company may store your personal data electronically, which may be impossible to erase. In such cases, the Company will arrange for the destruction or anonymization of such data.
  • 6.6 Right to Restrict Processing
    You have the right to request that the Company suspend the use of your data as required by law.
  • 6.7 Rectification Right
    If you believe that the data the Company holds is incorrect or you have changed your personal data, you have the right to request the Company to correct your personal data so that such personal data is correct, current, complete and not misleading.
  • 6.8 Right to Lodge a Complaint
    You have the right to lodge a complaint with the competent authorities under the Personal Data Protection Act B.E. 2562 if the Company violates or fails to comply with the said Act.

7. Security for personal data

  • 7.1 The Company will provide appropriate technical systems and management security measures to protect personal data related to you from accidental, illegal or unauthorized destruction, loss, access, use, alteration or disclosure.
  • 7.2 The Company shall review and enhance its security measures from time to time as necessary or as relevant technology is developed to ensure that the security measures are effective and appropriate in accordance with the minimum legal requirements as set by relevant government agencies.

8. Modifications to this Privacy Notice

The Company may amend this Privacy Notice from time to time and when such amendments or changes are made, the Company will post such amendments or changes on the website www.xxxx.com. If your consent is required, the Company will seek your consent in addition.

9. Contact Method

In case you have any questions or would like to inquire for more details about the protection of your personal data, the collection, use or disclosure of your data, the exercise of your rights or any complaints, you may contact the Company at "Contact Us". You agree that the Company’s discretion is final.