Whom it May Concern

     Guardforce Cash Solutions Security (Thailand) Company Limited and its Subsidiaries (collectively referred to as “Company” or “we” or “our”) gives highest priority to the protection of the personal data of the Customers, Trade Partners, the Persons Having Business Relationship and the Operators in Company Group (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, we 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, Company 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 Company, or other persons who contact and inquire for information of product and/or service of Company, 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 Company, 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 Company 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 Company.
  1.2 “Trade Partner(s)” means the person who will sell or sells product and/or provide service for Company, whether it has been registered as the trade partner of Company 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 Company 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 Company.
  1.3 “Person(s)" Having Business Relation” means the person which is not a customer, trade partner or the operator in Company 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 Company, 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 Company and such juristic person.
  1.4 “Operator(s) in Company” means the director, employee or other personnel which performs work pursuant to the policies or rules of Company.

2. Purposes for the collection, use and disclosure of personal data

  2.1 Whether you are a Customer, Trade Partner, the Person Having Business Relationship or the Operator in Company, Company 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 Company.	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 Company for dissemination or public relations through relevant channels such as internal email of Company, Company’s website, or other online media of Company such as Line, Facebook, Instagram, 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 Company in relation to the disbursement of payment of the accounting and finance unit of Company.	Legitimate interest basis
5.	For using as information in the proceedings in relation to Company’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 Company.	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 Company and/or using as an information for relationship management or relevant coordination in relation to Company including opinion survey for analysis and improvement of Company’s operation.	Legitimate interest basis
8.	For the disclosure of information necessary for the compliance with relevant evaluation criteria participated by Company.	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 Company or the related person for transparency and justification of all parties	Legitimate interest basis
10.	For the proceeding of management and administration concerning your heath, hygiene and safety such as the arrangement of health insurance	Legitimate interest basis
11.	For maintaining security in building area and premises of Company including the exchange of cards for the entry and exit of such area, the recording of videos of the visitors of Company or the buildings and premises of Company 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 Energy Regulatory Commission, Ministry of Energy, 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, Company may collect, use or disclose your personal data pursuant to the following purposes: For the performance measurement and the analysis on market survey and market strategies including for business planning, reporting and estimation For opinion survey, analysis, research and development of products, services and activities of Company to be more suitable with your requirement and for the development of communication and public relations to be suitable with your requirement 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. 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 Company 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, Company 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, Company 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 Company 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 Company including for surveying satisfaction concerning products and services of Company 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, and other relevant external authorities.	Legitimate interest basis

  2.3 In case that you are a Trade Partner, Company 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 Company, 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 Company’s bidders in accordance with procurement procedures of Company 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	Contractual and legitimate interest basis
2.	For the necessity in the conducting of transaction between Trade Partner and Company, 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 Company Consideration, preparation and execution of commercial agreements The compliance with hiring agreement, service agreement, other commercial agreements and relevant agreements or cooperation between Company 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 Company and Trade Partners, the administration of commercial supplies and products, the issuance of work certification until completion.	Legitimate interest basis
3.	For the compliance with relevant laws concerning the conducting of transactions between Trade Partners and Company such as the laws concerning procurement of state authorities, laws concerning taxation and etc.	Legal obligation basis

  2.4 In case that you are a Person Having Business Relationship, Company 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 Company or the projects relating to Company 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 Company, due diligence investigation on the status of business or other types of profile inspection and proceedings in accordance with relevant internal procedures of Company.	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 Company or the projects in collaboration between Company and the third parties or government authorities and the relevant proceedings in relation to such projects.	Legitimate interest basis

  2.5 In case that you are an Operator in Company, Company may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause	Purposes	Lawful Basis
1.	For identity verification as an Operator in Company	Legitimate interest basis
2.	For the compliance with relevant policies of Company, including inspecting the operation and compliance with Company’s policy	Legitimate interest basis
3.	For coordination with external authorities in relation to the conduct of Company’s business	Legitimate interest basis
4.	For using in order to support the consideration and selection of employees to perform work in Company, the Company may use your personal data for contacting and coordination, performing duties or conducting any transaction with third party, in the capacity of the representative of Company, or performing work as assigned by Company including the entering into agreements, the amendment to relevant contracts or agreements, the granting or obtaining of authority as well as providing clarification, information or statements to the third parties or participating in trainings, seminars, including for supporting the proceedings in accordance with internal procedures of Company, performance evaluation or payment of remuneration for work or welfare.	Contractual and legitimate interest basis
5.	For authority verification, granting or obtaining of authority including for using as supporting evidence for conducting relevant transactions.	Legitimate interest basis
6.	For using as supporting information for the checking of qualification or appropriateness on the performance of contracts or agreements	Legitimate interest basis
7.	For the provision of services under the contacts or agreements	Legitimate interest basis
8.	For work improvement or the provision of relevant services	Legitimate interest basis

In case that the personal data collected by Company 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, Company 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, Company shall collect your personal data by directly requesting the data from you; nonetheless, there may be some circumstances that Company 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, Company shall proceed to collect your personal data as follows:

   3.1 General personal data

• 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 company), driving license, Company’s defensive driving license, username, etc.
• Contact data such as address, a copy of house registration, phone number, facsimile number, email, Geolocation, emergency contract person, social media account, LINE ID, secretary information, etc.
• Financial data such as bank account number, etc.
• Communication data with Company such as information concerning date, time and place having contact with Company, information of the recording of video or voice upon having contact with Company, etc.
• 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.
• Data regarding educational profile, work profile, training, proficiency and relevant achievements, etc.
• Data regarding personal preferences and interest
• Recording of videos by closed-circuit television (CCTV)
• Data on the participation of meetings between Company and group companies including data on the participation of trainings, seminars, activities or other projects held by Company as there may be the recording of photo, video or voice during such meetings, trainings, seminars or activities
• Other necessary data for the legal proceeding or legal execution such as marriage status and data concerning assets, etc.
• Opinions, recommendations and complaints
• Records on the participation of relevant activities or projects with Company
• Screening data pursuant to communicable disease prevention measures
• Driving behavior while using Company’s car.
• Data concerning the utilization of relevant information systems of Company including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.
• 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, Company 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 Company 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 Company 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 Company is unable to conceal those data due to some technical limitation, Company shall collect and use such data as a part of your identification documents only. 

In case that it is necessary for Company to collect your sensitive personal data, unless otherwise prescribed by laws, Company 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 Company:

• Religious data
• Data concerning health and/or disability  

4. Period for retention of personal data

Company 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 Company 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 Company.

5. Disclosure of personal data

In order to carry out the proceedings for the purposes set out in this Privacy Notice, Company may disclose your personal data to the third parties as follows:

• The government authorities, 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, Department of Legal Execution, Office of the Attorney General, etc.
• 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 Company such as the parties of the case and witnesses, etc.
• Agents, contractors/sub-contractors and/or service providers for any operation provided for Company 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.
• 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)
• Management system standards certification institutes
• Shareholders
• Banks or financial institutions
• The transferee who received the assignment of any right, duty and benefit from Company 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.
• Other third parties such as the public relations of activity photos or news and information on the conducting of activities or projects of Company 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 Company has companies in the group which are located offshore. In addition, there are 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, Company 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, Company 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 COMPANY in Clause 9. In this respect, your relevant rights shall have details as follows:

  7.1 Right to withdraw consent
In case that Company 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 Company unless such withdrawal of consent is restricted by laws or by the agreement that provides you the benefits. Nevertheless, 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 Company, including to request Company to disclose the acquisition of such data that you have not given consent to Company.
  7.3 Right to request for the submission or the transfer of personal data
You have the right to request Company to transfer your personal data that you have given to Company 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 Company to delete your personal data as prescribed by laws. Nevertheless, Company may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, Company 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 Company 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 Company is incorrect or you have changed your personal data, you have the right to request Company 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 Company breaches or does not comply with such Act.

8. 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 Company’s 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 Company as per the following channels:

Attention :Data Protection Officer (DPO)

Email :PDPAcenter@guardforcecash.co.th

Address :PDPA Center Guardforce Cash Solutions Security (Thailand) Company Limited No.96 Vibhavadi Rangsit Road, Talad Bangkhen Sub - District, Laksi District, Bangkok 10210

Telephone :02 973 6000 Ext 333 or 339

For your acknowledgement 

Sincerely

Mr. Chu Kwok Wing
Managing Director