Thaicom Public Company Limited and its subsidiaries (hereinafter referred to as the “Company“) appreciate the importance of the rights and privacy of personal data owners (hereinafter referred to as “Data Subject(s)”) as well as the protection of personal data. Therefore, the Company hereby notifies you of the Company’s personal data protection policy, which contains the Company’s practices regarding the collection, use, disclosure of personal data, including the rights of Data Subjects, where the Data Subjects are customers, executives, employees, interns, contractors, business partners, visitors or any individuals entering the Company’s area under a closed-circuit television system (“CCTV”) surveillance of the Company including the areas within the Company’s premises and its vicinity.

This privacy notice (hereinafter referred to as the “Privacy Notice“) applies to any individual entering the Company’s areas under the Company’s CCTV surveillance including the areas within the Company’s premises and its vicinity. The Company collects, uses, and discloses personal data of Data Subjects as follows:

1. The Company may collect the following personal data of Data Subjects:

• Images recorded from CCTV cameras such as still and moving images, date and time, and areas under surveillance.
• Other data obtained from CCTV.

2. The purposes of the Company’s installation of CCTV are as follows:

2.1 To protect health and safety as well as property of Data Subjects.

2.2 To protect the Company’s premises, employees, and property from damage, interference, destruction, and other crimes that may occur.

2.3 To support the law enforcement in controlling, preventing, and detecting crimes, as well as supporting investigation or legal proceedings related to crimes or incidents.

2.4 To enable the Company to undertake necessary and appropriate actions to maintain the security of computer systems, electronic systems, electrical systems, telecommunications networks, or other systems used by the Company to provide services, protect the Company’s business operations, and ensure the safety of personnel, property, and premises of the Company, including mitigating, preventing, or limiting damages that may occur.

2.5 To enable the Company to enforce the rules and policies related to personal data and to protect the privacy rights of Data Subjects.

2.6 To enable the Company to comply with laws, regulations, and orders issued by competent authorities, such as laws on security, occupational health, and environmental conditions in the workplace.

2.7 To enable the Company to fulfil the objectives as authorized by law in its capacity as the data controller for the collection, use, or disclosure of personal data without obtaining consent from the Data Subjects.

The Company will install notice signs at entry and exit points and in areas under surveillance by CCTV to inform Data Subjects that the surrounding area is under CCTV surveillance. The cameras will operate 24 hours a day, every day, and may record audio. The Company will install CCTV in easily visible locations, and the Company will not install CCTV in such areas as employee break rooms, restrooms, changing rooms, showers, or other areas designated as rest areas for employees.

3. The Company may disclose the data from CCTV as follows:

3.1 The Company will keep personal data collected from CCTV confidential and will not disclose or transfer such data to any third party.

3.2 The Company may disclose data collected from CCTV as described in section 1 to supervisory agencies, governmental agencies, or agencies with legal or regulatory authority, where the Company deems it necessary to disclose personal data for the purposes in section 3.

3.3 In case the Company is required to disclose the data from CCTV to any organization or agency that does not meet the adequate standards for personal data protection as determined by the Personal Data Protection Committee, the Company will inform Data Subjects of the inadequate standards for personal data protection and must obtain consent from Data Subjects before disclosing such CCTV data.

4. The Company shall implement measures for the retention of personal data from CCTV and retention periods as follows:

4.1 The Company shall securely store and keep confidentiality of personal data and shall implement effective security measures in accordance with the law to prevent loss, unauthorized access to, use, alteration, or disclosure of personal data.

4.2 The Company shall retain personal data of the Data Subject for a period deemed necessary or appropriate, or as required by the statute of limitations, as well as in accordance with the Company’s standard for keeping documents, i.e., retention period of 30 (thirty) days from the last date of contact and identity verification with the Company or from the end of the Company’s relationship with the Data Subject unless a longer retention period is required due to legal proceedings. In such case, the Company may retain the personal data as long as necessary until the end of such proceedings.

4.3 Upon expiration of the data retention period, or once the Company can no longer assert a legal right to collect, use, and disclose the personal data, the Company shall proceed to delete, destroy, or anonymize personal data such that the Data Subject cannot be identified.

4.4 In the event of a data breach or violation of personal data, the Company has implemented measures to respond to such incident as follows:

4.4.1 Individual who becomes aware of the breach reports it to the Data Protection Officer.

4.4.2 The Data Protection Officer receives and records the incident.

4.4.3 The Data Protection Officer assesses the risk of the incident to determine whether it has any impact on the rights and freedoms of the Data Subjects.

4.4.4 In the case where there is no risk, the Data Protection Officer shall proceed as follows:

• Record the incident for future reference.
• Report the incident to the management.

4.4.5 In cases where a risk is identified, the Data Protection Officer shall take the following actions:

• Record the incident for future reference.
• Notify the Personal Data Protection Committee of the personal data breach within 72 hours of becoming aware of the incident.
• Report the incident to the executive management.

4.4.6 In cases of high risk, the Data Protection Officer shall proceed as follows:

• Record the incident for future reference.
• Notify the Personal Data Protection Committee of the personal data breach within 72 hours of becoming aware of the incident.
• Inform the Data Subjects of the breach, along with remedial measures.
• Report the incident to the management.

4.4.7 The Data Protection Officer shall conduct investigations to determine the cause of the personal data breach as well as to identify the root causes of the leakage or violation.

4.4.8 The Company shall improve the data leakage preventive measures.

5. Rights of the Data Subject under the personal data protection law are as follows:

5.1 The Data Subject has the right to give and withdraw his or her consent as follows:

5.1.1 In cases where the processing of personal data requires the consent of the Data Subject, the Data Subject has the right to give consent to the Company for the collection, use, and disclosure of personal data, to enable the Company to process personal data for the purposes notified to the Data Subject. Alternatively, the Data Subject may refuse to give such consent.

5.1.2 Once the Data Subject has given consent to the Company for the collection, use, and disclosure of personal data, the Data Subject may withdraw his or her consent at any time, unless there is a restriction of the withdrawal of consent by law or contract which gives benefits to the Data Subject.

5.1.3 In the event that the withdrawal of consent will affect the performance of the Company or the Data Subject in any manner, the Company shall inform the Data Subject of the consequences of consent withdrawal.

5.2 The Data Subject has the right to access his or her personal data which is under the responsibility of the Company.

5.3 The Data Subject has the right to obtain copy of personal data related to the Data Subject from the Company.

5.4 The Data Subject has the right to request the Company to disclose the acquisition of the personal data obtained without the Data Subject’s consent for the collection, use and disclosure.

5.5 The Data Subject has the right to receive the personal data concerning him or her from the Company where the Company has arranged such personal data to be in the format which is readable or commonly used by way of automatic tools or equipment and can be used or disclosed by automated means.

5.6 The Data Subject has the right to request the Company to transmit or transfer his or her personal data in the format specified in section 5.5 to another data controller where it is practicable through automated means.

5.7 The Data Subject has the right to obtain his or her personal data that the Company has transmitted or transferred as described in section 5.6 unless it is technically impracticable.

5.8 The Data Subject has the right to object to the collection, use, or disclosure of his or her personal data at any time. In case of Data Subject’s objection, the Company may continue to collect, use, or disclose the personal data only if it can demonstrate that there are compelling legal grounds for doing so.

5.9 The Data Subject has the right to request the Company to delete, destroy, or anonymize the personal data in the event that the personal data is no longer necessary to the Company in relation to the purposes stated in this Notice or in the event that the Data Subject withdraws consent for the personal data that requires consent or in the event that the collection, use, or disclosure of the personal data are unlawful.

5.10 The Data Subject has the right to request that the Company temporarily suspend the use of personal data while the Company is reviewing the Data Subject’s request to correct personal data or to object to unnecessary or unlawful collection of personal data.

5.11 The Data Subject has the right to request the Company to correct personal data to ensure that it is accurate, up-to-date, complete, and not misleading.

6. The Company is required to collect, use, and disclose personal data as specified by law. Nevertheless, the Company reserves the right to use personal data in situations where it is strictly necessary to communicate with the Data Subject.

7. The Company shall collect, use or disclose personal data in accordance with the applicable law currently in force. The Company is entitled to collect and use personal data that has previously been collected by the Company before the effective date of the Personal Data Protection Act for the original purposes. However, if the Data Subject does not wish the Company to continue collecting and using such personal data after the Personal Data Protection Act comes into force, the Data Subject may withdraw his or her consent through the method specified in section 8 of this Privacy Notice.

8. If the Data Subject has any question regarding this Privacy Notice or wishes to exercise the rights under section 5 or section 7, please contact the Company at Thaicom Public Company Limited, No. 349 SJ Infinite One Business Complex, 28th Floor, Vibhavadi Rangsit Rd., Chomphon, Chatuchak, Bangkok 10900, Telephone Number: (+66) 2-596-5095, or the Company’s website www.thaicom.net, or contact the Company’s Data Protection Officer at [email protected].

9. The Company may request the Data Subject to verify his or her identity prior to taking any action in case of the Data Subject’s exercise of the rights under section 5 or section 7.

10. The Company reserves the right to reject any exercise of rights of the Data Subject in accordance with the criteria specified by law. The Data Subject has the right to file a complaint with the Personal Data Protection Committee (PDPC) as specified by law.

11. The Company may revise this Privacy Notice from time to time and shall announce such revised Privacy Notice on the Company’s website. The revised Privacy Notice shall become effective on the date of announcement. In case any additional consent of the Data Subject is required, the Company shall request additional consent from the Data Subject.