HK Estate suggests our Subscriber understand this Privacy Policy, We provide this privacy notice to inform our customers of our policy concerning this policy, which prescribes the process of data collection, storage, use, and disclosure including other rights of Subscriber (“Data Subject”). Therefore, HK Estate would like to announce the Policy as follows:
Personal Data
“Personal Data” means any information pertaining to a Data Subject, which enables the identification of the Data Subject, whether direct or indirect.
Data collection
We collect, use, or disclose your personal data following:
Type of Personal Data | Personal Data |
Personal data |
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Sensitive Personal data |
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Sources of your personal data
We may get your personal data from the following channels:
Collect personal data directly from you (“Data Subject”)
Collect personal data from Other sources
Purpose of Collect, Use, or disclose your personal data
We will not use or disclose your personal data UNLESS it is necessary for the purposes set out above or disclosed to any person in the Company or the parties involved in the contract, as required by law, governmental authority, supervision organization, or with your consent.
Disclose personal data to others
The company will not disclose your personal information to other individuals and juristic persons who are not affiliated companies of the company (“other people”) unless it is disclosed to achieve the purpose of collecting and processing personal information as specified in this privacy notice. The company may disclose your personal information to other people such as
We may share or transfer your personal data to the following recipient to fulfill the purposes under this Policy. The recipients may be located or have the server(s) located in Thailand or outside Thailand. The recipients can be categorized as follows: (for each type including representatives its employees and directors)
(a) HK Management and Service Group Companies
As the HK Estate is under the HK Management and Service Group Companies, by the nature of the internal management, we may share or disclose your personal data to other entities within HK Management and Service Group Companies to fulfill and under the purposes of this Policy. To share and transfer, the company will make sure that your personal information will be shared or transferred safely and have an appropriate standard for the protection of personal data.
(b) Third Party Service Providers
The Company may share your personal data with third party service providers in the event that the Company hires or appoints third party service providers to process your personal data for/ on behalf of the company for the purposes specified in this Policy, including for website administrative management, delivery of products/services, marketing, data storage, IT solution, payment system.
(d) Business partners
We may share your personal data with our business partners when they jointly offer products or services jointly with us; or when we offer their products/services to you.
(e) Third parties required by law
To comply with the applicable laws or regulations, we may be required to disclose or share your personal information with competent authorities, courts, or any other persons, whose right is specifically defined by laws or if there is reason to believe that such disclosure is necessary to protect the rights of the Company or third parties.
Where the Company discloses or transfers personal data to any third parties, other than HK Management and Service Group Companies, the Company will enter into an agreement with the third party setting out the purposes of processing and the respective obligations of each party in place to protect data against unauthorized or accidental use, access, disclosure, damage, loss, or destruction.
Retention period of personal data
We will only retain the personal data for as long as necessary to fulfill the purposes for which we collected it and to the extent permitted by the Personal Data Protection Act B.E. 2562 or other applicable laws.
We have prepared schedules to specify the appropriate retention periods to ensure that when we no longer need to use your personal data we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.
Storage period
International transfer of personal data
Where your personal data is transferred to a third party or servers located outside Thailand, the company will take any necessary measures to ensure that personal data is transferred safely with appropriate privacy protection measures.
Right of Data Subject
You can exercise your rights under the PDPA, details as specified below, through the channels prescribed by us:
How security measures and quality of data
We have implemented (have required third parties to implement) appropriate technical and physical measures to safeguard and protect personal data from unauthorized or unlawful processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, personal data.
What are the marketing and promotional activities
Generally, the Company will only process only personal data that is necessary to fulfill and in a lawful manner, which the lawful basis can be classified, as follows:
1.The purpose for which we have obtained your consent
When we cannot rely on another lawful basis, we will request your consent for the purpose of marketing and communication, including offering products or services of us, our affiliates, or business partners.
Unless allowed or required by applicable laws, when we have to transfer your personal data to a country without adequate personal data protection standards for a personal data, we will request your consent before such transfer.
When you voluntarily provide your sensitive data to us, it means that you have permitted us to use your sensitive data for the following purposes:
(a) Health Information, including congenital disease, blood group, and food allergy, is collected for food preparation during the events.
(b) Religion is collected for the benefits of providing facilities to suit you;
(c) Race/Nationality may be collected when you provide the national registration identity card
(d) Criminal Record is collected for fraud prevention and security purposes
Please note that your sensitive data in the form of anonymized information may be used for statistical purposes to develop products or services that will be more suitable for you.
2.Contract
We may process your personal data where we need to perform under the contract that we are about to enter into or have entered into with you, whether verbal or written contract, which includes the following circumstances:
(a) Considering your eligibility and suitability before entering into a contract or providing a service to you.
(b) Taking any action in connection with contractual obligations between the Company and you, inkling contacting you to fulfill your obligation, sending the relevant documents.
(c) Verifying your identity when you prefer to exercise your rights under the contractual obligation between the Company and you.
3.Legitimate Interest
We may rely on our legitimate interests or third parties’ legitimate interests to process your personal data. In this case, necessity, the data subject’s fundamental rights and interests will be considered. The following circumstances constitute a legitimate interest:
(a) We may rely on our security purpose, including when we collect visitors’ information, request ID cards in exchange for visitor cards and record CCTV.
(b) We may rely on our internal management purpose, including when the company of HK Management And Service Group Companies enter into the event of merger or reorganization or similar event, we may transfer your personal data to third parties as part of such event on need to know basis.
(c) We may process your personal data to enhance and improve products and services for you and all customers of HK Management And Service Group Companies.
(d) We may process your personal data for marketing and communications purposes which will not materially affect the fundamental rights and the data subjects have the right to opt-out at any time.
(e) During the event, seminar, or any other sale events, whether the online or physical event, the photograph/ video, or audio may be recorded as a part of the event’s atmosphere.
(f) Where we have a relationship with any juristic person, we may collect personal data of relevant individuals, including copies of ID cards and contact details of authorized representatives.
(g) We may collect sales activities including interaction history, number of sales, appointment, or contact records for performance analysis and enhancement purposes.
4.Other legal basis for processing your personal data
In addition to legal grounds specified in 1. – 3., the Company may rely on other legal grounds to process your personal data, including where processing is necessary for compliance with a legal obligation; and where processing is necessary to protect the vital interests of a data subject or another person; where processing is necessary for performance of a task carried out in the public interest in the exercise of official authority vested in the controller. The other legal grounds are processing for various purposes, including:
(a) to comply with the requirement on the financial report required by auditors and/or government authorities and to cooperate with law enforcement entities, government authorities, regulators, and/or the court’s order regarding legal proceedings or investigation.
(b) to comply with the Computer Crime Laws in Thailand, we may need to record a Log file.
Notwithstanding the foregoing, we may use your anonymized data for any purpose without your consent.
What are the actions, practices, and policies regarding personal data
We reserve the right to update this policy for any reason, including but not limited to complying with relevant laws of Thailand, Thailand government policy, regulations, and other obligations of a similar nature.
Any changes to this Privacy Policy will become effective upon publishing the Privacy Policy.
Data Protection Officer
Attn: Personal Data Protection Office
Address: 36/159, Motorway Rd., Khlong Song Ton Nun Subdistrict,
Lat Krabang District, Bangkok 10250
Tel: 064-142-8888
081-462-6666
Email: info.hkestate@gmail.com
Edition as of September 4, 2024