Terms of use

Top Venture respects the right to privacy and values importance to the protection of Personal Data in connection with or in conducting transactions with Top Venture. Therefore, this privacy policy is prepared to provide governing criteria, mechanisms, measures and governance for managing Personal Data as follows:

1. Scope of this Privacy Policy

This Privacy Policy applies to all employees which includes permanent employees, employees with definite contract period, temporary workers and contractors including Data Processor who processes Personal Data on behalf of Top Venture.

2. Definition

2.1. “Personal Data” means data about a person that can directly or indirectly identify such person but does not include data of a deceased person in particular

2.2. “Sensitive Personal Data” means data that is a truly personal matter but is sensitive and may risk unfair discrimination such as race, ethnicity, political views, creed, religion or philosophy behavior, sexual behavior, criminal history, health data, disability, labor union data, genetic data, biological data or any other data that affects the Data Subject in the same way as prescribed by the Personal Data Protection Committee

2.3. “Processing” means actions relating to the collection, use, disclosure, deletion or destruction of Personal Data

2.4. “Data Subject” means natural person who is the owner of the Personal Data and such Personal Data is directly or indirectly identifiable to such person

2.5. “Data Controller” means person or juristic person having the authority to make decision about the collection, use, or disclosure of Personal Data

2.6. “Data Processor” means person or juristic person undertaking the collection, use or disclosure of Personal Data in accordance with an order or on behalf of Top Venture. Thus, this person or juristic person is not a Data Controller

3. Collection of Personal Data

3.1. Top Venture will collect Personal Data with purposes, scope and apply lawful and fair methods. The collection will be done only as necessary for the business objectives of Top Venture.

3.2. In the case of collection of Sensitive Personal Data, Top Venture will ensure that the Data Subject acknowledges and give consent to such collection via electronic method or other methods. Top Venture will explicitly request for consent from the Data Subject prior to the collection of Sensitive Personal Data unless such collection of Personal Data and Sensitive Personal Data falls under an exception provided under the Personal Data Protection Act B.E.2562 or other laws.

4. Purpose of Collection and Use of Personal Data

4.1. Top Venture will collect or use Personal Data for the benefit of Top Venture’s operations or to improve the quality and efficiency of work and/or to comply with laws or regulations applicable to Top Venture’s operations. Top Venture will collect and use such Personal Data only for the period necessary for carrying out the purpose as informed to the Data Subject or in accordance with what the law specified.

5. Disclosure of Personal Data

5.1. Top Venture will not disclose Personal Data to any persons without obtaining consent from the Data Subject and will only disclose in accordance with the informed purpose(s).

5.2. Top Venture may need to disclose Personal Data to its affiliates or other persons both within Thailand and in foreign countries for the benefit of Top Venture’s operations and provision of services to the Data Subject. In disclosing Personal Data to such persons, Top Venture will ensure that such persons maintain confidentiality of the Personal Data and refrain from using such Personal Data for any purpose other than those as specified by Top Venture.

5.3. Top Venture may disclose Personal Data under the requirements of the law such as disclosing Personal Data to government authorities, government agencies, regulator including in an event of request for disclosure made by virtue of the law.

6. Security of Personal Data

6.1. Top Venture will provide appropriate security measures for Personal Data and comply with the laws, policies, regulations, requirements and practices on the protection of Personal Data for the employees and other relevant persons.

6.2. Top Venture will support and encourage employees to have knowledge and awareness of duties and responsibilities for the collection, use, and disclosure of Personal Data so that Top Venture can comply with the Privacy Policy and Personal Data Protection laws correctly and efficiently.

7. Data Subject Rights

7.1. Right to access and request a copy of Personal Data about the Data Subject or right to request the sources of Personal Data Top Venture receives without the Data Subject’s consent.

7.2. Right to object the collection, use and disclosure of Personal Data of the Data Subject

7.3. Right to request for delete or destruction or anonymization of Personal Data

7.4. Right to restrict the use of Personal Data

7.5. Right to withdraw consent for the processing of Personal Data that has previously been given, in any cases such withdrawal will not affect the collection, use or disclosure of Personal Data that has already been consented for.

7.6. Right to request for correction of Personal Data

7.7. Right to Personal Data portability

8. Review and change of Privacy Policy

Top Venture may update or revise this Privacy Policy from time to time to comply with legal requirements, changes in Top Venture’s operations including opinions and suggestions from various agencies. Top Venture will announce changed for acknowledgement.

9. Contact Top Venture

Compliance Department Bangkok, Thailand Office&.active 555/1 Energy Complex Building A, 11th Floor, Vibhavadi Rangsit Road, Chatuchak Bangkok 10900 Phone: +66 (0)2 797 2999, +66 (0)2 299 0000 E-mail [email protected]