Privacy Notice for Customer

FOR PROCESSES RELATED TO CUSTOMERS OF PANTAINORASINGH MANUFACTURER CO., LTD.

1. General Provisions

For the purpose of complying with the Personal Data Protection Act B.E. 2562 (2019) and subordinate laws issued thereunder, including any amendments which may be made thereto (“Laws on Personal Data Protection”), Pantainorasingh Manufacturer Co., Ltd. (“Company”) has prepared this Personal Data Privacy Notice for processes related to customers of Pantainorasingh Manufacturer Co., Ltd. (“Privacy Notice”) to inform you regarding how the Company handles information which can or may identify you, whether directly or indirectly, according to the Laws on Personal Data Protection (“Personal Data”), such as the methods by which Personal Data is collected, used, disclosed or dealt with, whether by manual or automated means, such as recording, organization, storage, adaptation or alteration, retrieval, sending, transfer, disclosure or making available by any means, alignment, combination, prohibition of access or restriction, erasure or destruction (“Processing”, “Process”, “Processes” or “Processed”), as well as to notify you of the purposes for such Processing, the retention period of Personal Data, and your rights as the data subject. In this regard, the Company recommends that you read and understand the following terms under the Privacy Notice:

2. Groups or Categories of Persons Whom the Company Collects Personal Data

2.1 Customers – persons who purchase products and/or use services of the Company and/or those who are expected to purchase products and/or use the services of the Company (prospective customers), or any other persons having similar characteristics, such as persons who participate in activities, seminars, or bids, website users, application users, persons who make contact to request to receive information or services from the Company, and persons who provide responses to surveys concerning products and/or services of the Company, etc.

2.2 Persons related to customers – persons who are related to or are representatives of customers, such as executives, directors, employees, representatives, attorney-in-fact, or personnel of customers who are juristic persons, including persons whose Personal Data appear in relevant documents and processes, such as managers, purchasers, consignees, and cheque payers, etc.

3. How the Company Collects and Receives Your Personal Data

3.1 The Company collects and receives your Personal Data via the following methods:

(a) Personal Data which you directly provide to the Company

• When you engage in communications or make enquiries, provide comments or feedbacks to the Company, regardless of whether in written or oral communications through the website, application, by phone, e-mail, fax, mail, by face-to-face interaction or by any other means;
• When you express an intention to purchase products or use services of the Company, enter into a contract with the Company, or deliver documents containing Personal Data to the Company; and
• When you register through the website or the applications which are organized by or on behalf of the Company, including sign-in through third-party service providers; and
• When you participate in marketing activities or joining loyalty reward system, survey, questionnaire, or provide comments or feedbacks on products and/or services, lucky draws, events, or any other activities organized by or on behalf of the Company, etc.

(b) Personal Data which the Company automatically collects from you
The Company may collect your Personal Data by automated means such as the use of Cookies or other similar technologies. For more details, please see the Company’s Cookie Policy.

(c) Personal Data which the Company receives from third parties

• The collection of information from various service providers of the Company, such as website service providers, application service providers, e-commerce service providers, call center, service providers for public relations and products/services recommendation, and data collection service providers, etc.
• In some cases, the Company may collect your Personal Data from public data sources, data sources containing information relating to your business, or sources containing information relating to trades, irrespective of whether you have disclosed the Personal Data by yourself or have provided consent to somebody else to disclose such Personal Data.

3.2 In collecting your Personal Data, you will be informed of the details as set out in this Privacy Notice, including but not limited to, the lawful basis for the collection, use, disclosure and/or Processing of Personal Data in accordance with the lawful purposes, or in the event that the Laws on Personal Data Protection require your consent for any Processing of Personal Data, the Company will request your explicit consent.

3.3 Where the Company has previously collected your Personal Data before the Laws on Personal Data Protection have become effective, the Company will continue to collect and use your Personal Data in accordance with the original purposes of collection. In this regard, you have the right to withdraw your consent by contacting the Company using the contact details set out in Clause 10 of this Privacy Notice. However, the Company reserves the right to consider your request for the withdrawal of consent and proceed in accordance with the Laws on Personal Data Protection.

4. Collected Personal Data

4.1 Personal information, such as first name, last name, nickname, date/month/year of birth, age, sex, national identification number, photograph, and signature, etc.

4.2 Contact information, such as address as stated on the national identification card, address as stated in the house registration book, delivery address, billing address, telephone number, fax number, e-mail, social media accounts (e.g. Facebook, Instagram, Twitter, Line ID or third-party service providers, etc.), and details of person who may be contacted in case of emergency, etc.

4.3 Customer business information, such as details concerning the customer’s factory (such as name, registration number, location, and contact details, etc.), car number plate, and type of car, etc.

4.4 Information concerning sale and purchase transaction, such as customer code, order details (such as the wishlist product, the quantity and quality), details of complaints concerning the product (for example, the date of order, type of product, the relevant branch, and the problem that is found), etc.

4.5 Information concerning payment, such as the monetary amount, the credit limit, the payment terms, the account number, Personal Data which appears in the invoice, tax invoice, receipt, receipt voucher, and debit application form, etc.

4.6 Information concerning attention and behavior, such as behavior or trends to purchase products and/or services, user preference on social media, website, or the Company's public relation channels, etc.

4.7 Information that is used as supporting evidence in the Company’s customer registration or execution of transactions, such as Personal Data which appears in a copy of the national identification card, copy of passport, copy of house registration book, copy of change of name certificate, copy of factory license, registration form, copy documents of title over land, customer’s account opening form, documents certifying non-related parties, power of attorney, copy of company affidavit, copy of PhorPor. 09/20, map, security documents (such as title deed, bank guarantee, and personal guarantee), sale and purchase agreement or any other agreements relating to the transaction, and delivery order, etc.

4.8 Technical information, such as log file, IP Address and information regarding using behavior on website that the Company collects through the use of Cookies, and location data (e.g. Global Positioning System (GPS)) or other similar technologies, etc.

4.9 Other information, such as voice recording of conversations, and photo and video recording by means of CCTV, etc.

5. Purposes and Lawful Basis for the Collection, Use, Disclosure and Processing of Personal Data

5.1 The Company Processes your Personal Data for the following purposes and lawful bases (collectively, the “Purposes”):

(a) Analyzing and surveying customer behaviour – Consent basis: The Company interviews or surveys customers, or gathers data from third parties, by relying on customer consent.

(b) Selection of bidders and auction management – Legitimate interest basis: Qualification checks, communications, evidence collection; Contractual basis: Contracting with winning bidders and buying/selling products.

(c) Membership registration or customer account opening – Contractual basis: Processing new-customer requests; Legitimate interest basis: Account management and identity verification for juristic-person customers; Consent basis: Processing sensitive data (e.g., religion, blood group) on ID cards.

(d) Entering into agreements and providing collateral – Contractual basis: Agreement execution, credit-limit consideration, collateral provision; Legitimate interest basis: Contract management and customer qualification verification for juristic-person customers.

(e) Management of customer orders – Contractual basis: Performing sales/service agreements via any sales channel; Legitimate interest basis: Order management and identity verification for juristic-person customers.

(f) Product/service preparation and related transactions – Contractual basis: Shipment, billing, debt confirmation, receipt delivery; Legitimate interest basis: Customer communication for juristic-person customers.

(g) Preparing electronic tax invoices and receipts – Legal basis: Compliance with e-tax legislation and customer identification.

(h) Changing customer information in Company systems – Legitimate interest basis: Allowing customers or related persons to correct or update information.

(i) Receiving complaints – Legitimate interest basis: Facilitating complaints or comments to improve service quality.

(j) Public relations and marketing activities – Consent basis: Sending marketing messages, taking photos/videos for publicity, etc.

(k) Membership-system management – Contractual basis: Fulfilling member requests and account functions.

(l) Loyalty reward system management – Contractual basis: Recording/exchanging points, managing member ranking.

(m) Profiling within Pantainorasingh Group – Consent basis: Processing Personal Data for internal profiling to provide or promote Group products/services.

(n) Analyzing website/app/media use for service improvement or marketing – Legitimate interest basis: Improving digital platforms and product/service quality; Consent basis: Personalised marketing or where law requires consent.

(o) Communicating with customers – Legitimate interest basis: Communicating about products/services for which you are registered; Consent basis: Communicating about products/services for which you are not registered.

(p) Complying with laws and government orders – Legal basis: Compliance with taxation, PDPA and other applicable laws or orders.

(q) Establishment, compliance, exercise or defence of legal claims – Legitimate interest basis: Handling investigations, litigation and legal proceedings.

(r) Monitoring, protecting and ensuring security – Legitimate interest basis: Protecting Company property and security via CCTV, etc.; Vital interests basis: Preventing or suppressing danger to life, body or health.

(s) Transactions necessary or beneficial to you – Legitimate interest basis: Carrying out transactions directly related to the above purposes; consent obtained where law requires.

(t) Verification for exercising data-subject rights – Legitimate interest basis: Examining and verifying identity for rights requests.

(u) Other purposes to be notified later – The Company will give additional notice and obtain consent where required.

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5.2 Your Personal Data, which the Company will Process for the Purposes set forth in Clause 5.1 above that relate to the compliance with laws or contracts or are necessary for entering into contracts with you, is the data which is necessary for the achievement of the said Purposes. If you do not intend to provide such Personal Data to the Company, there may be legal implications or the Company may not be able to perform its duties pursuant to the contract which has been entered into with you or may not be able to enter into a contract with you (as the case may be). In such event, it may be necessary for the Company to decline to enter into the contract with you or to cancel the sale and purchase or the provision of any relevant services to you, whether in whole or in part.

5.3 In the event that the Company will Process your Personal Data in a manner and/or for purposes which are not consistent with the Purposes set forth above, the Company will put in place additional policies or notifications for the protection of Personal Data and/or send notice to you to provide explanations concerning such Processing of Personal Data. In this regard, you should review such additional policies or notifications in conjunction with this Privacy Notice (as the case maybe).

6. Disclosure of Personal Data

6.1 The Company may disclose your Personal Data in accordance with the Purposes and the rules prescribed under the laws to the following entities and persons:

(a) Pantainorasingh Group, both in and outside Thailand, including executives, directors, staff, employees and/or relevant in-house personnel, and as necessary on a need-to-know basis for the Processing of your Personal Data.‍

(b) Business partners, service providers, and data processors designated or hired by the Company to perform duties in connection with the management/Processing of Personal Data for the Company in the provision of various services, such as information technological services, data recording services, payment services, mailing services, delivery services, printing services, data analysis services, research services, marketing services, or any other services which may be beneficial to you or relevant to the Company’s business operation.‍

(c) Advisors of the Company, such as legal advisors, lawyers, auditors, or any other internal and external experts of the Company.‍

(d) Relevant governmental agencies which have supervisory duties under the laws or which have requested the disclosure pursuant to their lawful powers or relevant to the legal process or which were granted permission pursuant to applicable laws, such as Revenue Department, Ministry of Commerce, Office of the Personal Data Protection Commission, Office of Trade Competition Commission, Royal Thai Police, Office of the Attorney General, and court, etc.‍

(e) Any persons or other entities that you have given consent to disclose your Personal Data to, such as the disclosure of processed images of activities through various media platforms of the Company to the general public.

6.2 The disclosure of your Personal Data to third parties shall be in accordance with the Purposes or other purposes permitted by law, provided that if the law requires your consent to be provided, the Company will request for your prior consent.

6.3 In the event that the Company discloses your Personal Data to third parties, the Company will put in place appropriate safeguards to protect the Personal Data that has been disclosed and to comply with the standards and duties relating to the protection of Personal Data as prescribed by the Laws on Personal Data Protection. Where the Company sends or transfers your Personal Data outside Thailand, the Company will ensure that the recipient country, the international organization or such overseas recipient has a sufficient standard for the protection of Personal Data. In some cases, the Company may request your consent for the transfer of your Personal Data outside Thailand, subject to the requirements under Laws on Personal Data Protection.

7. Effect of Refusal of Providing Your Personal Data to the Company

If you refuse the Company to collect your Personal Data, the Company will not be able to proceed to align with the mentioned Purpose and you may not hold certain rights and benefits such as being a customer of the Company, entering into or performing the contract between you and the Company, orders management and products and/or services preparation, receiving the privilege benefits from the Company, etc.

8. Retention Period

The Company will retain your Personal Data for the period necessary to fulfil the Purposes for which the Personal Data was Processed, whereby the retention period will vary depending on the Purposes for which such Personal Data was collected and Processed. The Company will retain Personal Data for the period prescribed under the applicable laws (if any) by considering the statute of limitations under the laws for any legal proceedings that may occur from or in relation to the documents or Personal Data collected by the Company and having regard to the Company’s business practices and relevant business in relation to each category of Personal Data.

In this regard, if there is no relevant law specifying the retention period of the Personal Data, the Company will retain your Personal Data for the period not exceeding 10 years, starting from the date your legal relations/transactions with the Company come to an end. However, the Company may retain your Personal Data for a longer period of such time prescribed if the laws permit or such retention of Personal Data is necessary for the establishment of the right of claim of the Company.

After the period of time set forth above has expired, the Company will delete or destroy such Personal Data from the storage or system of the Company and other persons providing services to the Company (if any) or anonymize your Personal Data, unless in the event that the Company can continue to retain such Personal Data as prescribed by the Laws on Personal Data Protection or other applicable laws. In this regard, for additional details regarding the retention period of your Personal Data, you can contact the Company by using the contact details set out in Clause 10 of this Privacy Notice.

9. Your Rights in Relation to Personal Data

9.1 Right of Access – You have the right to access your Personal Data and may request that the Company provide you with a copy of such Personal Data in accordance with the requirements under the Laws on Personal Data Protection.

9.2 Right to Data Portability – You have the right to obtain your Personal Data, including to request that your Personal Data is transmitted to another data controller or to you, except where it is technically unfeasible, in accordance with the requirements under the Laws on Personal Data Protection.

9.3 Right to Object – You have the right to raise an objection to the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

9.4 Right to Erasure – You may request that the Company delete, destroy or anonymize your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

9.5 Right to Restriction – You have the right to request that the Company restrict the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

9.6 Right to Rectification – You have the right to request that your Personal Data be rectified if the Personal Data is inaccurate, not up-to-date, incomplete, or may cause a misunderstanding.

9.7 Right to Withdraw Consent – If the Company relies on your consent as the lawful basis for Processing your Personal Data, you have the right to withdraw such consent which has been provided to the Company at any time. However, the consent withdrawal may take a reasonable time to proceed with your request and will not affect the Processing that the Company has already done before such a consent withdrawal.

9.8 Right to Lodge a Complaint – If you have any concerns or questions about any aspect of the Company’s practices in relation to your Personal Data, please contact the Company using the contact details set out in Clause 10 of this Privacy Notice. Where there is reason to believe that the Company is in breach of Laws on Personal Data Protection, you have the right to lodge a complaint to the expert committee appointed by the Personal Data Protection Committee in accordance with the rules and methods prescribed under the Laws on Personal Data Protection.

However, the Company reserves the right to consider your request to exercise your rights and act in accordance with the requirements under the Laws on Personal Data Protection.

10. How to Contact the Company

The Company has designated Pantainorasingh Manufacturer Co., Ltd. as the coordinator for matters relating to the Company’s Personal Data protection. If you have any questions or would like to exercise your rights as set out in this Privacy Notice, you may contact the Company using the contact information provided below:

Pantainorasingh Manufacturer Co., Ltd.
E-mail: marketing@pantainorasingh.com

Address:
196/4 Pradipat Road, Samsen Nai, Phaya Thai, Bangkok 10400

Data Protection Officer
E-mail: privacy@pantainorasingh.com

Address:
196/4 Pradipat Road, Samsen Nai, Phaya Thai, Bangkok 10400

Telephone: +66 2 265 6999

11. Changes to This Privacy Notice

The Company may make changes to this Privacy Notice from time to time to reflect any changes to our Processing of your Personal Data and to comply with the changes to the Laws on Personal Data Protection or any applicable laws. In this regard, the Company will notify you of any significant changes to the Privacy Notice and the amended Privacy Notice through appropriate means. The Company encourages you to review such communication in order to be aware of any changes made to this Privacy Notice from time to time.

This Privacy Notice shall be effective from 24 June 2025.
Version 1.6 (Latest Updated 24 June 2025)