Personal Data Privacy Notice
For Customers, Trade Partners, the Persons Having Business Relationship

     Global Connections Public Company Limited (hereinafter referred to as “GC”) gives highest priority to the protection of the personal data of the Customers, Trade Partners and the Persons Having Business Relationship (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, GC 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, GC 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 GC, or other persons who contact and inquire for information of product and/or service of GC, 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 GC, 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 GC 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 GC.
     1.2 “Trade Partner(s)” means the person who will sell or sells product and/or provide service for GC, whether it has been registered as the trade partner of GC 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 GC 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 GC.
    1.3 “Person(s) Having Business Relation” means the person which is not a customer, trade partner 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 GC, 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 GC and such juristic person.

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, GC 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 GC.

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 GC for dissemination or public relations through relevant channels such as internal email of GC, GC’s website, Facebook, LINE, YouTube or other online media of GC 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 GC in relation to the disbursement of payment of the accounting and finance unit of GC.

Legitimate interest basis

(5)

For using as information in the proceedings in relation to Know Your Customer and/or Due Diligence concerning GC’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 GC.

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 GC and/or using as an information for relationship management or relevant coordination in relation to GC including opinion survey for analysis and improvement of GC’s operation.

Legitimate interest basis

(8)

For the disclosure of information necessary for the compliance with relevant evaluation criteria participated by GC.

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 GC 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 GC such as field trip activity, technical visit, site visit, receiving donation, seminar, training project or other projects of GC or the projects that GC 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 including the exchange of cards for the entry and exit of such area, the recording of videos of the visitors of GC or the buildings 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 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, GC may collect, use or disclose your personal data pursuant to the following purposes:

  1. For the performance measurement and the analysis on market survey and market strategies including for business planning, reporting and estimation;
  2. For opinion survey, analysis, research and development of products, services and activities of GC to be more suitable with your requirement and for the development of communication and public relations to be suitable with your requirement;
  3. 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.;
  4. 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 GC;
  5. 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 GC as well as keeping as database of the profile of activity participants of GC;

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, GC 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, GC 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 GC 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 GC including for surveying satisfaction concerning products and services of GC 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, GC 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 GC, 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 GC’s bidders in accordance with procurement procedures of GC 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 GC, 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 GC;
  • Consideration, preparation and execution of commercial agreements;
  • The compliance with hiring agreement, service agreement, other commercial agreements and relevant agreements or cooperation between GC 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 GC 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 GC 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, GC 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 GC or the projects relating to GC 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 GC, due diligence investigation on the status of business or other types of profile inspection and proceedings in accordance with relevant internal procedures of GC.

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 GC or the projects in collaboration between GC and the third parties or government authorities and the relevant proceedings in relation to such projects.

Legitimate interest basis

     In case that the personal data collected by GC 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, GC 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, GC shall collect your personal data by directly requesting the data from you; nonetheless, there may be some circumstances that GC 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, GC shall proceed to collect your personal data as follows:
3.1 General personal data
     (1) 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 GC Group), driving license, GC’s defensive driving license, username, etc.;
     (2) Contact data such as address, a copy of house registration, phone number, facsimile number, email, Geo-location, emergency contract person, social media account, LINE ID, secretary information, etc.;
     (3) Financial data such as bank account number, etc.;
     (4) Communication data with GC such as information concerning date, time and place having contact with GC, information of the recording of video or voice upon having contact with GC, etc.;
     (5) 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.;
     (6) Data regarding educational profile, work profile, training, proficiency and relevant achievements, etc.;
     (7) Data regarding personal preferences and interest;
     (8) Recording of videos by closed-circuit television (CCTV);
     (9) Data on the participation of meetings between GC and group companies including data on the participation of trainings, seminars, activities or other projects held by GC as there may be the recording of photo, video or voice during such meetings, trainings, seminars or activities;
     (10) Other necessary data for the legal proceeding or legal execution such as marriage status and data concerning assets, etc.;
     (11) Opinions, recommendations and complaints;
     (12) Records on the participation of relevant activities or projects with GC;
     (13) Screening data pursuant to communicable disease prevention measures;
     (14) Driving behavior while using GC’s car.
     (15) Data concerning the utilization of relevant information systems of GC including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.;
     (16) 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, GC 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 GC 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 GC 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 GC is unable to conceal those data due to some technical limitation, GC shall collect and use such data as a part of your identification documents only.
     In case that it is necessary for GC to collect your sensitive personal data, unless otherwise prescribed by laws, GC 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 GC:
     (1) Religious data;
     (2) Data concerning health and/or disability;

4. Period for retention of personal data
     GC 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 GC 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 GC.

5. Disclosure of personal data
     In order to carry out the proceedings for the purposes set out in this Privacy Notice, GC may disclose your personal data to the third parties as follows:
     5.1 The government authorities, regulatory authorities, state enterprises, state authorities, public organizations, 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, the Office of Securities and Exchange Commission, Anti-Money Laundering Office, Department of Labour Skill Development, Welfare and Labour Protection Department, Energy Business Department, Ministry of Natural Resources and Environment, Ministry of Transport, Ministry of Energy, Office of the Ombudsman, State Audit Office of Thailand, House of Representatives Committee, House of Senate Committee, Department of Legal Execution, Office of the Attorney General, State Audit Office of Thailand, the Office of National Anti-Corruption Commission, National Science and Technology Development Agency, etc.;
     5.2 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 GC such as the parties of the case and witnesses, etc.;
     5.3 Agents, contractors/sub-contractors and/or service providers for any operation provided for GC 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.;
     5.4 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);
     5.5 Management system standards certification institutes;
     5.6 Training participants;
     5.7 Shareholders, debenture holders and the representatives of such persons;
     5.8 Banks or financial institutions;
     5.9 The transferee who received the assignment of any right, duty and benefit from GC 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.;
     5.10 Other third parties such as the disclosure or the announcement of relevant persons who have been selected through social media channels of GC or the public relations of activity photos or news and information on the conducting of activities or projects of GC 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 GC 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, GC 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, GC 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 GC in Clause 9 or through GC website, whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to GC. In this respect, your relevant rights shall have details as follows:
7.1 Right to withdraw consent
     In case that GC 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 GC 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 GC, including to request GC to disclose the acquisition of such data that you have not given consent to GC.
7.3 Right to request for the submission or the transfer of personal data
     You have the right to request GC to transfer your personal data that you have given to GC 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 GC to delete your personal data as prescribed by laws. Nevertheless, GC may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, GC 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 GC 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 GC is incorrect or you have changed your personal data, you have the right to request GC 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 GC breaches or does not comply with such Act.

8. Amendment of this Privacy Notice
     GC may amend and update this Privacy Notice from time to time, and if there is such amendment, we will keep you posted through GC 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 GC as per the following channels:

Global Connections Public Company Limited
Office Address: 13/1 Moo2 Kingkaew Rd, Rachateva, Bangplee, Samuthprakarn 10540
Telephone : 0 2763 7999
E-mail : compliance@gc.co.th

Announced 1 July 2022