Personal Data Protection Notice of Protollcall Advanced Services Co.,Ltd.
for Customer, Trade partner, Work Candidate and Employee
Protollcall Advanced Services Company Limited (“Protollcall”) operates its business in adherence with ethical standards and respect for your privacy. Protollcall has always placed importance on personal data protection and security to ensure that your personal data obtained by Protollcall will be used in accordance with the objectives and in compliance with law. Protollcall has formulated this personal data protection notice (this “Notice”) to inform you, as a data subject, of the objectives and details for collection, use and / or disclosure of personal data, including your legal rights.
To whom will this Policy apply ?
Customers include Individuals having involvement with a juristic person who is using or has used products and / or services and a person who requests data on products and / or services.
Trade partners such as suppliers, sponsors, dealers, sellers, contractors, service providers, buyers, etc., or individuals or juristic persons having involvement with trading of Protollcall.
Work Candidate and employee include a person in the family, beneficial owner, a contact person or referred by Protollcall’s employee.
Which personal data does Protollcall collect, use, and / or disclose ?
1.Personal data is the data that can directly or indirectly identify you, i.e
The personal data that you give directly to Protollcall or through Protollcall ’s contact channels such as website, email, meeting, online social media, application, interview, training, or employment or data on Protollcall’s website via cookies or other technology.
The personal data received or accessed by Protollcall from other sources such as business partners, consortiums, Recruitment agencies, or public data sources.
personal data does Protollcall collect, use, and / or disclose ie.
| Type of data | Examples of data |
|---|---|
| Identity Data | Example Title/ first name/ middle name/ last name/ alias (if any)/ gender/ date of birth/ age/ nationality/ signature/ photo/ etc. |
| Contact Data | Example address per important document/ workplace/ telephone number/ mobile phone number/ facsimile/ email/ contact name/ online social media (such as LINE ID)/ etc. |
| Financial Data | Examples Deposit account number/ salary slip/bonus or evidence showing other income/ Provident Fund/ Group Health Insurance/ Tax ID number and data on personal tax payment/ etc. |
| Education and work information | Examples data on a copy of the transcript/ the highest education level/ career and professional field/ position/ current years of work/ work detail/ etc. |
| Technical data/devices/equipment | Examples IP address/ MAC address/ International Mobile Equipment Identity (IMEI)/ Cookies ID/ Audit Log/ Data on login/ access period/ usage and usage period of application and website/ search history/ browsing data etc. |
| Other information | Examples the marital status/ family status/ number of family members and children/ data of relationships (parents/ beneficiary/ contact person/ and reference person) etc. |
2. Sensitive Personal Data
“Sensitive Personal Data” means personal data which is specifically determined by law. Protollcall has no intention to collect Sensitive Personal Data from you.
In certain cases, however, Protollcall may need to collect Sensitive Personal Data from you for providing contract or compliance with the order of the court, the government agencies, for example, religion or data on criminal records, Health record data, biometric data (such as facial recognition data, fingerprint recognition data), etc. Protollcall shall collect, use and/or disclose the Sensitive Personal Data provided that Protollcall has been given explicit consent by you or permitted by law. This shall be undertaken on a case-by-case basis when Protollcall is required to collect Sensitive Personal Data from you.
(Unless specifically stated otherwise, personal data and Sensitive Personal Data as earlier mentioned shall hereinafter be collectively referred to as “Personal Data”.)
3.Personal Data of any other third party
If you provide the Personal Data of any other third party who has involvement with you to Protollcall such as family members, reference persons, emergency contact persons and / beneficiary, etc., please inform those persons of the details under this Policy and request their consent, if necessary, or apply other lawful bases to ensure that Protollcall can collect, use and/or disclose Personal Data of the aforementioned third party.
What are the objectives of collection, use and / or disclosure of your Personal Data ?
Protollcall will collect, use and/or disclose your Personal Data only as necessary under Protollcall’s legitimate objectives which include the collection, use and/or disclosure of Personal Data for compliance with the contract in which you are a contracting party, for the performance of duties as required by law, for legitimate interest, for operations according to your consent and/or for operations under other lawful bases. Objectives for collection, use and/or disclosure of Personal Data under this Policy are as follows.
In case that you are a Customer, Protollcall may proceed on the Processing of your personal data for additional relevant purposes as follows:
| Items | Objectives | Lawful Basis |
|---|---|---|
| 1 | such as giving information/ consultation/ advice and/or any other data related to products and/or services/ analysis and assessment of customer demand/ verification of qualification/ verification of juristic person customer’s status/ check of data or document accuracy/ identification/ and authentication/ including know – your – customer (KYC). Any operation related to consideration of products and/or services such as communication/ receipt/delivery of documents or parcels/ processing of the request/ operation per the request approval procedure/ billing/ etc. | Consent Basis/ Contractual Basis/ Legitimate Interests |
| 2 | For the benefit in the evaluation/ improvement/ and development of products/ the provision of services/ and relevant sales promotions of Protollcall including for surveying satisfaction concerning products and services of Protollcall so that they are appropriate and suitable to your requirement etc. | Legitimate Interests |
| 3 | For using as information and supporting documents for any proceeding with banks/ financial institutions/ Department of Business Development/ Revenue Department/ compliance with the order of the court/ government agencies/ and other relevant external authorities. | Legitimate Interests |
In case that you are a Trade Partner, Protollcall may proceed on the Processing of your personal data for additional relevant purposes as follows:
| Items | Objectives | Lawful Basis |
|---|---|---|
| 1 | For proceedings in accordance with relevant procedures prior to entering into an agreement such as consideration of qualifications of Trade Partner/ preparation of information before entering into the purchasing/ attending the clarification/ the presentation concerning purchasing/ price bargaining/ verification of authority/ the granting or obtaining of authority for submission of documents. Including the case of the service provider/ legal advisor/ accounting advisor/ business advisor and tax advisor/ auditor/ financial advisor/ advisor on accounting/ and preparation of the confidentiality agreement. | Contractual Basis/Legitimate Interests |
| 2 | For the necessity in the conducting of transactions between Trade Partner and Protollcall/ such as consideration/ preparation/ and execution of commercial agreements/ compliance with the hiring agreement/ service agreement/ other commercial agreements/ and relevant agreements or cooperation between Protollcall and Trade Partners. | Contractual Basis/Legitimate Interests |
| 3 | For compliance with relevant laws concerning the conducting of transactions between Trade Partners and Protollcall such as laws concerning taxation. | Legal Obligation |
In case that you are a work candidate or an employee, Protollcall may proceed on the Processing of your personal data for additional relevant purposes as follows:
| Items | Objectives | Lawful Basis |
|---|---|---|
| 1 | Collect sensitive personal data for any specific purpose that Protollcall could not rely on any lawful basis for the processing/ Protollcall shall request your prior express consent. In this regard Protollcall may process the following sensitive personal data Religious data/ and disability/ Biometric data for the consideration and selection of the participants of the training/ and seminar or maintaining security in the building area – Health data for the procedures necessary for the consideration and selection of work candidates/ benefitting rights (e.g. medical expense reimbursement/ insurance disbursement/ Provision of vaccination services or sent for treatment) – Criminal history to consider recruiting for selection to work and qualification check. | Consent Basis |
| 2 | selection consideration and employment/ such as recruiting and verification of identity. Verifying the accuracy of information and documents. The job applicant selection process (e.g. job applicant qualification/ interviews/ written exams)/ communication/ contracting/ and/or related juristic acts. The employment process (e.g. issuing employee cards/ employee registration/ employee information/ preparing the equipment for work). Performance of the contract to which you are a party; or to process your request/application before entering into a contract. | Contractual Basis |
| 3 | Human resource management/ such as input on employee databases and employee profiles/ facilitating the work of hiring-related meetings. Use of your information in the transaction of Protollcall and in performing the duties of the committee of Protollcall – in connection with liaising with external service providers. business partner or government agencies (for example sending employee information to hospitals or government agencies to receive vaccinations) – time off/ leave of absence/ appointment/ transfer/ change of position reorganization Performance Assessment and Management | Contractual Basis/Vital Interest |
| 4 | Payment of wages or other compensation such as welfare or other benefits/ compensation/ payments/ and salaries. Employee benefits (e.g group insurance/ air travel insurance) | Contractual Basis |
| 5 | Skills development such as organizing training and personnel development to promote employee learning. | Contractual Basis |
| 6 | Other Protollcall’s operations such as audio recording/ image/ CCTV – Checking the Use of Electronic Devices To increase work efficiency or to monitor cyber threat – Prosecution or other legal processes/ required by law and/or notices by Protollcall and any action relating to dismissal. | Contractual Basis/ Legitimate Interests/ Legal Obligation |
| 7 | For compliance with laws or compliance with a court’s summon/ letter or order of authorities or officers having duties and powers under the laws such as PDPA/ Civil and Commercial Law/ insurance law/ labor protection law/ social security law/ workmen’s Compensation Law/ Tax Law – including regulations and rules issued under these laws/ which are now being enforced/ to be amended or to be enforced in the future. | Legal Obligation |
For Personal Data that Protollcall has previously collected before the effective date of this law, Protollcall shall continue to collect and use such Personal Data for the original purposes. However, if you do not wish Protollcall to continue collecting and using your Personal Data, you can request Protollcall withdraw the consent whenever you want.
To whom will your Personal Data be disclosed ?
Protollcall may disclose your Personal Data to a third party Under your consent or criteria permitted by law. Persons or agencies receiving such Personal Data will collect, use and/or disclose your Personal Data within the scope for which you have given consent, or within the scope related to this Policy. In certain cases, you may be under the personal data protection policy of such recipient of your Personal Data. The recipient of your Personal Data may be in Thailand or other countries.
Protollcall may disclose your Personal Data to persons or agencies as follows :
| Persons or agencies | Details |
|---|---|
| Service providers | Protollcall may use another company/ trade partner/ Protollcall’s agent/ subcontractor/ or external service provider to conduct business operations on behalf of Protollcall or to support the provision of Protollcall’s products and/or services to you. Therefore Protollcall may disclose your Personal Data to Protollcall’s service provider/ including event organizers/ life insurance companies/ training services/ and hospitality services (e.g. hotels/ and hospitals). |
| Protollcall’s business partners | Protollcall may disclose your personal data to Protollcall’s business partners. |
| Persons determined by law | In some cases Protollcall may be required to disclose your personal data for compliance with the order of persons having legal authority or legal rights and/or for compliance with the law. The recipients of your Personal Data include law enforcement agencies/ The Revenue Department/ the Office of Personal Data Protection Commission/ the Office of Consumer Protection Board/ or any other person as necessary to perform duties under laws or regulations or for protection of Protollcall’s rights/ third party’s rights/ which may include any related legal procedures. |
| Advisors / experts | For the benefit of Protollcall’s business operation/ Protollcall may disclose your Personal Data to external auditors/ Human resource advisors/ data analysis advisors/ or other advisors or experts/ as the case may be. |
| Any other third party | Protollcall may disclose your Personal Data to any other third party for the objectives as specified in this Policy. Any other third party receiving your Personal Data may include Protollcall’s customers/ your new employer/ or the public. |
Will Protollcall send or transfer your Personal Data to other countries ?
Protollcall does not need to send or transfer your Personal Data to any recipient in other countries.
How long does Protollcall keep your Personal Data ?
Protollcall will keep your Personal Data during the period you are Protollcall’s employee, or you have a relationship with Protollcall, or throughout the period required in order to achieve the related objectives of this Policy. Once your relationship with Protollcall ends, Protollcall will further keep your Personal Data for a period as necessary according to the statute of limitations or for a period as required or permitted by law, for instance:
Customers/Trade Partners : Protollcall shall retain your personal data for the period necessary for the purposes of the collection, to utilize your personal data in accordance with the purposes and after the end of the relationship, it shall be further retained pursuant to the period necessary for the compliance with laws or the statutory prescription period.
Work Candidate : if Protollcall has not considered accepting your employment in the position applied for, Protollcall shall retain such personal data of you for the period of 3 months as from the date of application.
The director, employee : Personal Data shall be kept in accordance with labor protection law, and other related laws, for 10 years after the end of the relationship.
Protollcall will undertake operations through appropriate steps to delete or destroy the Personal Data or make it anonymous when it is no longer necessary or said period ends.
How does Protollcall protect your Personal Data ?
Protollcall shall apply technical, administrative, and physical safeguard measures for the safekeeping of your Personal Data in order to maintain confidentiality, accuracy, completeness, and availability of Personal Data to prevent unauthorized or illegitimate access, collection, revision, rectification, use, and/or disclosure of Personal Data in accordance with legal requirements.
Protollcall has put in place appropriate measures to prevent the infringement of Personal Data. Protollcall has therefore established policies, procedures, and criteria for Personal Data protection such as measures to control access to Personal Data and use of secure and proper devices for storing and processing Personal Data, restriction of access to Personal Data, determination of user’s right to access Personal Data, right to permit assigned employees to access Personal Data and users’ responsibilities in order to prevent unauthorized access to Personal Data, unauthorized disclosure, unauthorized knowledge or unauthorized copy of Personal Data, or theft of devices used for storing or processing Personal Data. The measures have thus been put in place for tracking back of access to, change in, deletion, or transfer of Personal Data, which are consistent with and appropriate for the methods and tools for collection, use, or disclosure of Personal Data, including examination for assessing the effectiveness of compliance with policies, procedures, and criteria for Personal Data protection.
Protollcall’s executives, employees, personnel, contractors, representatives, advisors, and recipients of data from Protollcall shall maintain the confidentiality of Personal Data in accordance with the confidentiality measures determined by Protollcall.
Your rights as the owner of personal data
As the owner of personal data, you can exercise your rights. Your relevant rights having detailed as follows:
1.Right to withdraw consent (opt – out): You shall have the right to withdraw the consent for the processing of your personal data that has already been given to Protollcall unless the 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.
2.Right of access: You have the right to request access to and request a copy of your personal data under the control of Protollcall, including to request Protollcall to disclose the acquisition of such data that you have not given consent to Protollcall.
3.Right to rectification: You have the right to request Protollcall to correct your personal data so that such personal data be accurate, current, and complete.
4.Right to erasure: You have the right to request Protollcall to delete your personal data as prescribed by laws.
5.Right to restriction of processing: You are entitled to request Protollcall to suspend the use of Personal Data.
6.Right to data portability: You have the right to request Protollcall to transfer the personal data that you have given to Protollcall as prescribed by laws.
7.Right to object: You have the right to object to the processing of data relating to you in respect of the collection, use, or disclosure of your personal data as prescribed by laws.
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 Protollcall breaches or does not comply with such an Act.
In case that you find that Protollcoll does not comply with the Personal Data Protection Law, you have the right to complain to the Personal Data Protection Committee. or a supervisory authority appointed by the Personal Data Protection Committee or by law. Protollcoll would like the opportunity to be informed of the facts and clarify various issues and manage your concerns at the first opportunity.
You can request to exercise your rights at dpooffice@protollcall.com
However, you do not pay any fees for the above rights, Protollcall will consider and notify the result of the consideration according to your request within 30 days from the date that Protollcall received the request. The exercise of your right may be limited under applicable law and there are instances where it is necessary that Protollcoll may refuse or fail to fulfill your above request for example to comply with a law or a court order. for public benefit, The exercise of rights may infringe upon the rights or freedom of others, etc. If Protollcoll denies the above request Protollcall will also inform you of the reason for the refusal.
Penalties for non-compliance with the Privacy Policy
Protollcall’s employees whose operation in relation to Personal Data violates or fails to comply with the provisions of this Act which causes damages to the data subject shall compensate the data subject for such damages, regardless of whether such operation is performed intentionally or negligently. Such a person shall also be punished with the punishment as prescribed for such an offense.
Amendment of this Privacy Notice
Protollcall may amend and update this Privacy Notice from time to time, and if there is an amendment, we will keep you posted through Protollcall website. Announced on 15 August B.E. 2564 (2021)
Contact channels
If you have questions 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 Protollcall as per the following channels:
Contact Place: Protollcall Advanced Service Co.Ltd. Unit B600 Fl.6, Promphan 2, Ladprao Soi 3, Chatuchak, BKK, 10900, Thailand
Email : dpooffice@protollcall.com
