Privacy Policy

1. Introduction

Thai Premium Pipe Co., Ltd. (“the Company”) processes your personal data to support its business operations and to ensure compliance with applicable laws and regulations. The Company is committed to protecting the privacy and security of your personal data.

This Privacy Notice (“Notice”) has been prepared to inform you, as the data subject, of the purposes and details of the collection, use, and/or disclosure of your personal data, as well as your rights under the applicable data protection laws in relation to your personal data.

2. Definitions

For the purposes of this Privacy Notice, the following terms shall have the meanings set out below:

“You” means any data subject whose personal data is processed by Thai Premium Pipe Co., Ltd., including but not limited to stock exchanges, investors, shareholders, website users, customers, business partners, contractors, visitors, individuals who contact the Company, professionals engaged in the Company’s business, employees, personnel, representatives, and any other individuals involved in the Company’s activities and business operations.

“Personal Data Protection Laws” means the Personal Data Protection Act B.E. 2562 (2019) of Thailand, together with its subordinate legislation, regulations, and any amendments or replacements thereto that may be enacted from time to time.

“Personal Data” means any information relating to an identified or identifiable natural person, whether directly or indirectly, but excludes information relating specifically to deceased persons, as provided under the Personal Data Protection Laws.

“Processing” means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including but not limited to collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure (by transmission, transfer, publication, or otherwise making available), alignment or combination, restriction, erasure, or destruction.

“Data Controller” means a natural person or a juristic person who has the authority to make decisions regarding the collection, use, or disclosure of Personal Data.

“Data Processor” means a natural person or a juristic person who processes Personal Data on behalf of, or under the instructions of, the Data Controller. A Data Processor does not have the authority to determine the purposes and means of processing Personal Data and is therefore not considered a Data Controller.

3. General Information

This Privacy Notice explains how Thai Premium Pipe Co., Ltd. collects, uses, discloses, processes, and retains your personal data. It also outlines the purposes of processing, the retention period, and your rights as a data subject. As a manufacturer, processor, and distributor of steel products, the Company processes personal data in compliance with the applicable personal data protection laws of Thailand.

4. Collection of Personal Data

4.1 We collect your personal data through the following channels:
Directly from you: When you contact us, submit forms (online or offline), apply for a job, request our products or services, participate in activities, subscribe to marketing communications, or provide feedback.

Automatically: When you visit our website, we may automatically collect technical information, browsing data, and usage information through cookies and similar technologies. For more information, please refer to our Cookie Policy.

From third parties: We may receive your personal data from third parties, including business partners, service providers, financial institutions, government authorities, regulatory bodies, recruitment agencies, or other lawful sources.

4.2 When collecting your personal data, we will inform you of the relevant details as required under this Privacy Notice, including the legal basis for collecting, using, and disclosing your personal data. Where your consent is required by applicable data protection laws, we will obtain your explicit consent before processing your personal data.

5. Personal Data We Collect

5.1 Under this Privacy Notice, Thai Premium Pipe Co., Ltd. may collect personal data relating to the following categories of data subjects, whether obtained directly or indirectly:

Customers, shareholders, and investors, including individual shareholders, website visitors, customers, service users, service providers, and any individuals who contact us to request information or services.

Business partners and related parties, including individuals who are parties to, or associated with, contracts or business relationships with Thai Premium Pipe Co., Ltd., such as suppliers, vendors, contractors, consultants, professional advisors, service providers, and other persons involved in our business operations.

Personnel, including employees, workers, directors, executives, consultants, interns, and other individuals engaged by Thai Premium Pipe Co., Ltd., as well as their family members where relevant for employment administration and the provision of benefits.

Applicants, including individuals who submit job or internship applications, résumés, or other personal information to Thai Premium Pipe Co., Ltd., whether in writing or verbally, for the purpose of applying for employment or internship opportunities. This category also includes, where relevant, the applicants’ family members and referees.

5.2 We may collect your personal data directly from you, automatically through your use of our services or systems, or from third parties. Depending on your relationship with Thai Premium Pipe Co., Ltd. and the purposes of processing, the categories of personal data we collect may include:
Personal identification information, such as your full name, date of birth, age, gender, photograph, passport or national identification card details, signature, nationality, marital status, and information relating to your family members.

Sensitive personal data, such as religious beliefs, criminal records, health information, medical examination results, disability information, and biometric data, where permitted or required by applicable law.

Contact information, such as your residential or mailing address, telephone number, email address, social media contact details, and emergency contact information.

Financial information, such as your bank account details, payment information, and tax-related information.

Securities and investment information, where applicable, such as securities or derivatives trading account details, dividend or interest payment information, securities deposit and withdrawal records, securities transfer records, and pledge registration information.

Account and system usage information, such as your account credentials, profile information, account activity, records of changes to your account, usage of our websites, applications, systems, and services, preferences, feedback, participation in our activities, and records of your communications with Thai Premium Pipe Co., Ltd. or our representatives.

Technical and usage information, such as IP address, device identifiers, device and browser type, operating system, mobile network and connection information, geolocation data, website or application usage data, access and login records, transaction logs, system activity logs, referring websites, search history, customer behavior, access time, and information collected through cookies and similar technologies. We may also collect records of your communications and interactions with other users through our systems, where applicable.

Education and employment information, such as educational background, training records, academic transcripts, certificates, qualifications, language proficiency, professional licenses and registration details, employment history, job title, start date, salary or compensation, performance of duties, training and assessment records conducted by Thai Premium Pipe Co., Ltd. or relevant organizations, and other employment-related information.

Audio, visual, and CCTV records, such as photographs, video recordings, audio recordings, and CCTV footage collected in connection with our business operations, security, training, or other legitimate purposes.

5.3 Where the Company collected your Personal Data prior to 1 June 2022, the Company will continue to process such Personal Data in accordance with the requirements of the applicable Personal Data Protection Laws.

6. Purposes and Legal Bases for the Collection, Use, and Disclosure of Personal Data

6.1 We process your personal data for the following purposes (collectively, the “Specified Purposes”) and on one or more of the following legal bases:

Performance of a Contract – where processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
Legal Obligation – where processing is necessary for compliance with our legal obligations.
Legitimate Interests – where processing is necessary for our legitimate interests or those of a third party in connection with our business operations, provided that such interests are not overridden by your fundamental rights and freedoms. We implement appropriate safeguards to protect your rights and interests.
Consent – where your consent is required by applicable law or where no other legal basis applies. In such cases, we will process your personal data only for the purposes communicated to you and for which your consent has been obtained.

Where we request your specific consent for the processing of any personal data, we will process such data only for the purposes notified to you and consented to by you.

We will process Sensitive Personal Data only where permitted by applicable law or with your explicit consent, as required.

Specified Purposes

Legal Basis for Processing

(a) To comply with legal obligations applicable to Thai Premium Pipe Co., Ltd., including applicable laws and regulations relating to contracts, securities, taxation, labor protection, computer-related offenses, personal data protection, and any other relevant laws, as amended from time to time.

(b) To perform our contractual obligations and provide our products and services, including the production, processing, and distribution of steel products in domestic and international markets, the administration of contracts and transactions, the operation and improvement of our websites, applications, electronic systems, and networks, the provision of corporate and annual report information, the recording of website visits and customer service communications, the verification of your identity, and the provision of shareholder and investor services, including information relating to dividends, shareholders’ meetings, and share subscription rights.

The processing of your personal data is necessary for the performance of a contract to which you (or the organization you represent) are a party, to take steps at your request prior to entering into a contract, to comply with applicable laws or court orders, or for the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities.

(c) To process and respond to your requests or inquiries, record photographs, audio, and video for service, security, and operational purposes, and carry out the legitimate business activities of Thai Premium Pipe Co., Ltd.

The processing of your personal data is necessary for the performance of a contract to which you (or the organization you represent) are a party, to take steps at your request prior to entering into a contract, to comply with applicable laws, regulations, or court orders, or for the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities.

(d) To promote, develop, and share knowledge with our stakeholders, and to ensure the effective delivery of our products, services, and information. This includes organizing training programs, supplier audits and site visits, corporate social responsibility (CSR) activities, educational initiatives, stakeholder engagement programs, and operating related websites and applications. We may also record photographs, audio, and video in connection with these activities.

The processing of your personal data is necessary for the performance of a contract to which you (or the organization you represent) are a party, to take steps at your request prior to entering into a contract, to comply with applicable laws, regulations, or court orders, or for the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities.

(e) To communicate with you, manage our relationship with you, provide customer support, respond to your inquiries, requests, suggestions, or complaints, verify your account information, and deliver our products and services. We may contact you by telephone, SMS, email, postal mail, or other communication channels.

We may also process your personal data to improve our products and services, conduct business analytics, market research, statistical analysis, and product development, personalize your experience, provide targeted marketing and promotional communications, deliver relevant content, advertisements, and recommendations, and record photographs, audio, and video in connection with our business activities and customer services.

The processing of your personal data is based on the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities, or where necessary for research or statistical purposes in accordance with applicable laws.

(f) To manage human resources and recruitment processes, including evaluating applicants, recruiting, appointing, employing, or engaging employees, workers, consultants, and interns, and administering employment-related matters.

This includes managing payroll, compensation, benefits, training, workplace facilities, occupational health and safety, social security, provident funds, health insurance and other employee welfare programs, maintaining employment and health records where required, improving recruitment and HR systems, communicating recruitment opportunities, recording photographs, audio, and video in connection with HR activities, and ensuring compliance with internal policies and applicable laws.

The processing of your personal data is necessary for the performance of an employment contract or to take steps prior to entering into such contract, to comply with applicable laws, regulations, or court orders, or for the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities.

(g) To manage procurement and purchasing activities with you (or the organization you represent), including supplier evaluation, qualification and selection, contract negotiation and administration, the purchase of goods and services, warranty management, payment processing, invoicing and debt collection (where applicable), and the management of our business relationship with you.

We may also process your personal data to communicate with you, record photographs, audio, and video in connection with procurement activities, and comply with applicable accounting, taxation, withholding tax, and other legal requirements.

The processing of your personal data is necessary for the performance of a contract to which you (or the organization you represent) are a party, to take steps prior to entering into a contract, to comply with applicable laws, regulations, or court orders, or for the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities.

(h) To maintain the security of our premises, systems, networks, and information technology infrastructure, including monitoring the use of our services, providing Wi-Fi and other IT services, improving cybersecurity measures, and protecting our information assets. Where appropriate, personal data may be encrypted or otherwise processed using appropriate security measures.

We may also process your personal data to manage access to our premises, monitor and investigate security incidents, prevent, detect, and investigate fraud, unauthorized access, theft, fire, violence, or other unlawful activities, and record photographs, audio, video, and CCTV footage for security and safety purposes.

The processing of your personal data is based on the legitimate interests of Thai Premium Pipe Co., Ltd. or other relevant persons or entities to ensure the security, safety, and integrity of our premises, personnel, assets, systems, and information.

(i) For any other purposes notified to you at the time your personal data is collected. Where Thai Premium Pipe Co., Ltd. intends to use your personal data for a purpose other than those described above, or to change the original purpose of processing, we will notify you accordingly and, where required by applicable law, obtain your consent before processing your personal data. Such notification may be provided through the contact details you have supplied to us.

6.2 Where the processing of your personal data is necessary for compliance with legal obligations, the performance of a contract, or to take steps prior to entering into a contract as described in Section 6.1, you are required to provide such personal data. If you do not provide the required personal data, Thai Premium Pipe Co., Ltd. may be unable to comply with its legal obligations, perform its contractual obligations, or enter into a contract with you (as applicable). In such circumstances, Thai Premium Pipe Co., Ltd. may refuse to enter into a contract with you or suspend or terminate the provision of all or part of the relevant services.

6.3 Processing for Additional Purposes

Where the Company intends to process your Personal Data for purposes not described in this Privacy Notice, the Company will provide you with an additional Privacy Notice explaining the relevant processing activities.

You should read any such additional Privacy Notice together with this Privacy Notice to understand how your Personal Data will be processed for those additional purposes.

7. Recipients of Personal Data

7.1 We may disclose your personal data, where necessary and in accordance with applicable laws, to the following parties:

Our directors, officers, employees, and authorized personnel who require access to your personal data for the purposes described in this Privacy Notice.

Government authorities, regulatory bodies, and law enforcement agencies, where disclosure is required or permitted by law or legal process.

Business partners, service providers, contractors, and data processors engaged by the Company to provide services on our behalf, including IT system management, cybersecurity, payment processing, auditing, human resources, and other business support services.

Other organizations or persons as required by law or where necessary to protect the Company’s legal rights or comply with legal obligations.

7.2 We will disclose your personal data only for the purposes stated in this Privacy Notice or as otherwise permitted or required by applicable law. Where your consent is required by law, we will obtain your explicit consent before disclosing your personal data.

7.3 Where we disclose your personal data to third parties, we will implement appropriate technical and organizational measures to safeguard your personal data and ensure compliance with applicable personal data protection laws.

7.4 Where we transfer your personal data to recipients outside Thailand, we will ensure that appropriate safeguards are in place and that the destination country, international organization, or recipient provides an adequate level of personal data protection in accordance with applicable data protection laws. Where required by law, we will obtain your consent before transferring your personal data internationally.

8. Retention of Personal Data

8.1 We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and processed. The retention period may vary depending on the nature of the personal data, the purpose of processing, and our legal or regulatory obligations.

8.2 We will retain your personal data for the period required by applicable laws and in accordance with our business practices. Upon the expiration of the applicable retention period, your personal data may be securely deleted, destroyed, or anonymized from our systems without prior notice, unless otherwise required by law.

9. Personal Data of Minors

The Company’s products and services are not intended for minors as a primary target audience.

However, due to the nature of the Company’s business, products, and services, the Company may, from time to time, collect and process Personal Data relating to individuals under 20 years of age.

In such cases, the Company will process the Personal Data of minors in accordance with the applicable Personal Data Protection Laws. Where required by law, the Company will obtain consent from the minor’s parent, legal guardian, or other person exercising parental authority before collecting, using, or disclosing the minor’s Personal Data.

10. Rights of Data Subjects

As a data subject, you are entitled to exercise the following rights in relation to your Personal Data, subject to the conditions, procedures, and limitations prescribed under the applicable Personal Data Protection Laws.

If you wish to exercise any of your rights, please contact the Company using the contact details provided in Section 13 (Contact Us) of this Privacy Notice.

10.1 Right of Access
You have the right to access your personal data and request a copy of such data. You may also request information about how we obtained your personal data where it was collected, used, or disclosed without your consent, to the extent permitted by applicable personal data protection laws.

10.2 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format. Where technically feasible, you may also request that we transfer your personal data to another data controller or directly to you, in accordance with applicable personal data protection laws.

10.3 Right to Object
You have the right to object to the processing of your personal data where we process it based on our legitimate interests, the legitimate interests of a third party, or for the performance of a task carried out in the public interest. We may continue processing your personal data where we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defense of legal claims.

You also have the right to object to the processing of your personal data for direct marketing purposes. If you wish to exercise your right to object, please specify whether you request the deletion of your personal data or that we cease processing it, subject to applicable laws.

10.4 Right to Erasure
You have the right to request that we delete or anonymize your personal data where:
your personal data is no longer necessary for the purposes for which it was collected or processed;
you withdraw your consent, and there is no other legal basis for processing your personal data;
you object to the processing of your personal data in accordance with Section 10.3;
your personal data has been unlawfully collected or processed.

This right does not apply where the processing of your personal data is necessary to comply with legal obligations, exercise the right to freedom of expression, or establish, exercise, or defend legal claims, as permitted by applicable law.

10.5 Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in the following circumstances:
where you contest the accuracy of your personal data, pending verification;
where your personal data should be deleted under Section 10.4, but you request that its processing be restricted instead;
where we no longer need your personal data, but you require it for the establishment, exercise, or defense of legal claims; or
where you have objected to the processing of your personal data under Section 10.3, pending verification of whether our legitimate grounds override your objection

10.6 Right to Rectification
You have the right to request that we correct or update your personal data to ensure that it is accurate, complete, current, and not misleading.

10.7 Right to Withdraw Consent
Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.

10.8 Right to Lodge a Complaint
If you have any questions or concerns regarding our processing of your personal data, please contact us using the details provided in Section 13 (Contact Information).

If you believe that we have processed your personal data in violation of applicable personal data protection laws, you have the right to lodge a complaint with the Personal Data Protection Committee (PDPC) or the relevant supervisory authority.

We will use reasonable efforts to respond to your requests promptly. However, we may refuse or be unable to comply with a request where it would impose an unreasonable burden, adversely affect the rights or personal data of others, conflict with applicable laws, or is otherwise impracticable.

11. Security of Personal Data

The Company has implemented appropriate technical, organizational, and administrative measures to safeguard your Personal Data against unauthorized or unlawful access, collection, use, disclosure, alteration, loss, destruction, or other forms of unlawful processing.

The Company maintains appropriate security mechanisms and selects suitable data storage systems in compliance with the applicable Personal Data Protection Laws and other relevant laws. Access to your Personal Data is restricted to the Company’s directors, employees, authorized personnel, and service providers who have a legitimate need to access such information in the performance of their duties.

The Company continuously reviews and improves its security measures to ensure that your Personal Data remains adequately protected throughout its processing lifecycle.

12. Links to Third-Party Websites, Products, and Services

The Company’s websites, applications, products, or services may contain links to third-party websites, applications, products, or services. These third parties may collect information relating to your use of their websites, applications, products, or services.

This Privacy Notice applies solely to the collection, use, disclosure, and other processing of Personal Data carried out by the Company for the purposes described in this Privacy Notice. The Company is not responsible for the privacy practices, security measures, or content of any third-party websites, applications, products, or services, even where you access them through links provided on the Company’s websites or services.

You are encouraged to review the applicable privacy notices or privacy policies of such third parties before providing any Personal Data or using their websites, applications, products, or services.

13. Contact Information

If you have any questions regarding this Privacy Notice or wish to exercise any of your rights under this Privacy Notice, please contact the Company using the following details:

Thai Premium Pipe Co., Ltd.
Website: https://www.thaipremiumpipe.com

Human Resources Department
Thai Premium Pipe Co., Ltd.
45 Moo 2, Chaimongkol Subdistrict,
Mueang Samut Sakhon District,
Samut Sakhon 74000, Thailand

Telephone: 034-845438–41
Fax: (+66) 34-845-442
Email: hr@thaipremiumpipe.com

Alternatively, you may contact the Company’s Data Protection Officer (DPO) using the following details:

Email: chanakan.l@thaipremiumpipe.com

14. Governing Law

This Privacy Notice shall be governed by and construed in accordance with the laws of the Kingdom of Thailand.

Any dispute arising out of or in connection with this Privacy Notice shall be subject to the exclusive jurisdiction of the competent courts of Thailand.

15. Changes to this Privacy Notice

The Company may amend or update this Privacy Notice from time to time to reflect changes in the processing of your Personal Data, applicable Personal Data Protection Laws, or other relevant laws and regulations.

Where any material changes are made, the Company will notify you through appropriate communication channels, as required by applicable law.

The Company nevertheless recommends that you review this Privacy Notice periodically to stay informed of any updates.

This Privacy Notice is effective as of 30 May 2022.

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