Personal Data Privacy Notice
For the Lodging of Complaint, the Whistleblowing of Corruption and the Claim for Compensation or the Legal Proceeding against the Third Party

     Global Connections Public Company Limited (hereinafter referred to as “GC”) gives highest priority to the protection of the personal data of all related persons, and for the compliance 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:
     • when you lodge relevant complaints including the whistleblowing of corruption to us;
     • when GC reaches out to you for the request of additional data concerning the complaint lodged by the other person;
     • when you committed action in a manner that causes damages to GC whether it be the action against the property or the reputation of GC including to inform you of the rights on your personal data and our contact channels as follow:

1. Purposes for the collection, use and  disclosure of personal data
     When there is a lodge of complaint or the whistleblowing of corruption to GC, we may conduct the processing of your personal data by relying on relevant lawful basis for the following purposes:

Clause

Purposes

Lawful Basis

1.1

For contacting and inquiring additional information concerning the complaints in which you or other person have reported to us.

Legitimate Interest basis 

1.2

For the proceedings in relation to the management of relevant complaints as well as the proceedings in accordance with internal procedures of GC, for instance, the consideration to proceed, fact investigation, fact finding, fact inquiry or disciplinary investigation, the retention of data as the records of the proceedings, the retention and the use of data for risk management, audit supervision, the development of the products and the provision of services including the internal audit of the internal audit office and the proceedings in accordance with other internal procedures of GC including the proceedings for the handling of complaint reported by external authorities such as the regulatory authorities.

Legitimate interest basis

1.3

For the establishment, compliance, exercise or defense of legal claim and relevant legal proceedings including for using as the supporting evidence of the legal proceeding (if any) against related person as well as the proceedings for legal execution.

Legitimate interest and legal obligation basis

1.4

For the compliance with the relevant laws including the reporting and disclosure of data to the government authorities or any organization pursuant to laws or by court order.

Legal obligation basis

     In the event that you are the third party, that is not the employee, vendor, or any person having transaction relating to GC, and had committed any action in the manner that causes damages to GC, GC may collect, use and disclose your personal data under relevant lawful basis for the following purposes:

Clause

Purposes

Lawful Basis

1.5

or contacting, inquiring, making an appointment or any contact including notifying you to suspend the action that causes damages to GC or settle the dispute.

Legitimate interest basis

1.6

For the proceedings in accordance with internal procedures of GC such as the consideration to proceed, fact investigation, fact finding, fact inquiry or disciplinary investigation, the retention of data as the records of the proceedings, the retention and the use of data for risk management, audit supervision, the development of the products and the provision of services including the internal audit of the internal audit office and the proceedings in accordance with relevant internal procedures of GC.

Legitimate interest basis

1.7

For the establishment, compliance or exercise or defense of legal claim and other legal proceedings including for using as supporting evidence of the legal proceeding (if any) to related person as well as the proceedings for legal execution.

Legitimate interest and legal obligation basis

1.8

For the compliance with relevant laws including the reporting or the disclosure of information to government authorities or any organization pursuant to the laws or by court order.

Legal obligation basis

2. Personal Data which shall be collected
     In case that you are the person who lodged a complaint or the whistleblower of the corruption, GC shall collect your personal data through the form, letter or relevant documents in which you provided data for us or by other methods, that is, the requesting of the data from you directly; nonetheless, there may be some circumstances that we collect your personal data from other sources such as the data publicly disclosed on websites (such as the website of the Department of Business Development or the website of the National Anti-Corruption Commission, etc.) or the data that is capable for requesting a copy from the government authorities, or in case that you lodge a complaint to the regulatory authorities or other authorities, GC may obtain your data from such authorities or GC may receive your data from the case that you have been referred to in the complaint of other person, etc. In the event that you are the third party, that is not the employee, vendor, or any person having transaction relating to GC, and have committed any action in the manner that causes damages to GC, GC may collect your personal data by directly requesting your personal data from you, or may collect your personal data from other sources such as inquiring from the witnesses of the incident, collecting the data publicly disclosed on websites or the data that is capable for requesting a copy from the government authorities, etc.
     In this regard, the personal data that we shall collect are as follows:
2.1 General personal data
     (1) Identity data such as first name and last name, etc.;
     (2) Contact data such as address, phone number, email, Facebook, LINE ID or other social media accounts, etc.;
     (3) Other data such as occupation, workplace, position, details of the complaint, details of the action causing damages to GC, etc.;
     (4) Data of financial status, data of the status of being bankrupt, data of personal assets (such as the disclosure of assets prior to accepting the position), shareholding data (only for the case
     that your complaint is related to such data or the case that GC is required to use such data for supporting the legal proceeding).

2.2 Sensitive personal data

     For the lodging of complaint or the whistleblowing of corruption, GC has no intention to collect and use sensitive data such as religious and nationality, etc. of yours or other person for any specific purpose. You are not required to specify or refer to such data; nonetheless, some type of complaint which is directly related to the exercise of rights against GC such as the claim for GC to pay for damages or relevant compensations, etc., you may be required to provide sensitive data supplementing the complaint such as health data, data regarding disability, etc. For such case, GC may collect your data for supporting the establishment, compliance or exercise or defense of legal claim. In this regard, if we will use such data for any other purpose apart from this, we shall request for your prior express consent (if necessary).
     In the event that you are the third party, that is not the employee, vendor, or any person having transaction relating to GC, and have committed any action in the manner that causes damages, GC may collect sensitive personal data to the extent necessary for supporting the establishment, compliance or exercise or defense of legal claim. In this regard, if we will use such data for any other purposes apart from this, we shall request for your prior express consent (if necessary).
     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 such document with concealed data shall be deemed 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

3. 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 the determination of the retention period are the period necessary for the compliance with the laws or the statutory prescription period, or for the establishment, compliance, exercise or defense of legal claim, or for other reasons in pursuant to the internal policies and rules in the organization of GC.

4. 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 party as follows:
     4.1 Government authorities, independent organizations established pursuant to the laws or other authorities as prescribed by laws whether it be the disclosure pursuant to the laws prescribing
GC the duty to disclose such data, or the disclosure as requested by such authorities by the virtue of the laws such as the National Anti-Corruption Commission, State Audit Office, etc. and including the disclosure of data to the officers which exercise powers or perform duties according to the laws such as police, etc.;
     4.2 Regulatory authorities of GC such as the office of the Securities and Exchange Commission (SEC), etc., in case that such authorities have powers according to the laws for the requesting of data or in case that such authorities submit the complaint for GC’s consideration;
     4.3 State authorities, independent organizations established pursuant to the laws or other authorities as prescribed by laws which have powers and duties to conduct inquiry, investigation, interrogation or to commence legal proceeding such as police, public prosecutor, court, etc.;
     4.4 Agents, contractors/sub-contractors and/or service providers for any operation assigned by GC such as legal advisors, insurance companies, etc.;
Nonetheless, if you are the person who lodged a complaint or the whistleblower of the corruption or the witness pursuant to such complaint, GC would like to inform you that we shall keep your personal data confidential pursuant to our internal policies and rules and shall not disclose the data to any person having no connection with the management and administration of such matter.
In the event that it is necessary for us to disclose your personal data, we shall comply with our internal policies and rules as well as this Personal Data Privacy Notice and relevant laws.

5. 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 exercise your relevant rights through the channels specified by GC in Clause 7 or through GC website, whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to GC. The relevant rights having details as follows:
5.1 Right to withdraw consent
     In the event 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.
5.2 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.
5.3 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.
5.4 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.
5.5 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 system 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.
5.6 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.
5.7 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 shall not cause misunderstanding.
5.8 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.

6. 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 GC website. If it is necessary to request for your consent, we will proceed to request additional consent from you.

7. Contact channels
     If you have question or require further details concerning the protection of your personal data, the collection, use and disclose 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