Privacy Policy
LTMH Public Company Limited (hereinafter referred to as “the Company” or “we”) greatly value the importance of protection of your personal data and treat it with utmost respect as it is part of our social responsibility and as the cornerstone for ensuring the security of personal data. Therefore, the Company hereby declares and affirms an unwavering commitment to fully comply with law on personal data protection and other relevant regulations.
Whereas, this policy has been duly formulated for the purposes of informing and clarifying the details pertaining to the collection, use, disclosure, and management of personal data by the Company in accordance with the provisions set forth in the Personal Data Protection Act B.E. 2562 (2019) and other relevant regulations of the following categories of data subjects:
- The Company's business partners, either as persons or representatives of juristic persons.
- Persons involved in or appearing in any form of media produced and/or published by the Company.
- Employees including but not limited to full-time, part-time, contract employees of the Company, job applicants desiring to join the Company, including their family members, references, and emergency contacts of employees or job applicants.
1. Data Collection
Personal data the Company collects from you
| Categories of Data | Example |
|---|
| Personal Details | Name-surname, date of birth, national identification number, passport number, gender, age, nationality, photograph, signature, marital status, and spouse's information. |
| Contact Information | Address, telephone number, email address, LINE ID, or social media accounts. |
| Transaction and Financial Information | Bank account number, credit card number. |
| Media Production Information | Photographs, videos, voice recordings, interview transcripts or content. |
| Employee Information | Educational history, employment history, marital status, military status, licenses, welfare and benefit information, work performance and disciplinary data, third-party information (family members, guarantors, references, emergency contacts), social security information. |
| Sensitive Personal Data | Religion, health data (e.g., blood type, medical history), genetic data or biometric data (e.g., fingerprints). |
If you refuse to provide any information that is deemed necessary for the preparation or execution of the contract or required by law, The Company hereby reserves the right to refuse to enter into a contract or cease performance of any of obligations under existing contracts, or we may terminate any existing relationship with you.
2. Purposes of Personal Data Usage
Based on the personal data we have received, we collect, use, or disclose personal data for the following purposes:
| Purpose | Detail |
|---|
| Entering into contract, performing contract, or conducting various transactions | - To enter into and perform the contract.
- To carry out payment or conduct other related transactions.
- For business communication purposes with you as an employer, contractor, or representative of juristic persons.
|
| Compliance with legal requirements | - In order to carry out business operations to comply with the obligations under applicable laws, rules and regulations enforced by competent legislative e.g., law on personal data protection, law on tax, law on labor, law on social security, law on immigration including court orders or orders or directives issued by government agencies.
- For the purposes of cooperating with or complying with investigations conducted by law enforcement officials, or other competent regulatory authorities.
|
| Preparing and disseminating information | - For the purposes of utilizing photographs, videos, audio recordings, or other content featuring or pertaining to you in the production, creation, and dissemination of videos, posts, articles, or other media materials.
- For the purposes of disseminating such media materials through online platforms or other channels and mediums.
|
| Legitimate interests of the Company or other persons | - For the purposes of improving and developing the Company's business operations e.g., analyzing data usage, conducting audits, developing new products, enhancing or modifying existing services, evaluating and analyzing service utilization, conducting promotional campaigns, surveys or marketing activities, assessing and planning the Company's operational strategies and business expansion initiatives. Provided that any such activities shall be carried out through processes that anonymize and de-identify the personal data, ensuring that data subjects cannot be identified from the data, and subject to appropriate technical and organizational measures to safeguard the security and confidentiality of the data.
- For the purposes of detecting, investigating, preventing and responding to any acts or potential acts that may constitute a violation or contravention of applicable laws.
- For the purposes of protecting the Company's business operations, as well as safeguarding the privacy rights, security, or property interests of the Company, its personnel, data subjects, or other individuals.
- For the purposes of conducting internal investigations, or audits in areas such as security and safety matters, operational performance.
- For the purposes of maintaining internal security within the Company, as well as remedying, preventing, or mitigating potential harm or damages that may arise.
- For the purposes of engaging in business communications and interactions with representatives or persons associated with juristic persons who are business partners, counterparties, or contracting parties of the Company.
- For the purpose of communicating with individuals who have a relationship or association with the Company's employees in cases of urgent necessity or inquiring about important information related to employees.
|
3. Disclosure of Information
We disclose personal data in the following situations:
- We disclose your personal data to service providers and consultants who require access to personal data to perform services for us, such as companies that assist us with web hosting, data storage and infrastructure, analytics, payment processing, fraud prevention and security, customer service, communication, and marketing services.
- We may disclose your personal data if we believe that such disclosure is in accordance with legal processes, such as in response to a court order or a request from a law enforcement agency with legal authority. If we are required to disclose your personal data in legal proceeding, we will inform you, unless we are legally prohibited from doing so or we believe that such an action would endanger others or constitute illegal conduct. In any event, we will protect privacy and object to requests for information about Blockdit users that we believe are not in accordance with legal procedures or are otherwise improper.
- We share personal data with our professional advisor and counsel when we seek their advice or to protect and manage our business interests.
- We share personal data in connection with a corporate mergers, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal data will be shared among and between our current and future affiliates, including but not limited to other companies under common ownership and control.
- We share personal data with your consent or at your direction.
- We share aggregated, statistical, or de-identified information that cannot reasonably be used to identify you.
4. Personal Data Management and Data Retention Period
The Company has implemented appropriate security measures for personal data to prevent loss, unauthorized access, use, alteration, modification, or disclosure of personal data. These measurements include limiting access to personal data. Additionally, the Company required our employees, staff, representatives, and recipients of data from the Company to maintain the confidentiality and security of personal data in accordance with defined standards.
We will retain your personal data until it is no longer necessary for the provision of services or for the purposes specified in section 2 above. This retention period will depend on the nature, characteristics, or technical limitations of each type of data, the purposes for which the data is collected and used, applicable laws, or retention requirements. For example, data related to contracts and transactions between us may be stored for a minimum of 10 years.
5. Your Rights Regarding Personal Data
Under law on personal data protection, you have the following rights regarding your personal data, unless we have legal grounds to refuse your request:
- Right to withdraw consent - You have the right to withdraw any consent previously given. The withdrawal of consent shall not affect the collection, use, and disclosure of personal data for which you have already given consent.
- Right to access and obtain a copy of personal data - You have the right to access and obtain a copy of your personal data that we have collected.
- Right to receive or request the transfer of personal data - You have the right to receive your personal data in a format that is readable or commonly used by automatic tools or devices and can be used by automated means. You also have the right to request that we send or transfer your personal data to third party, or to receive personal data that we have sent or transferred to third party.
- Right to object - You have the right to object to the collection, use, and disclosure of your personal data that we carry out under the legitimate interests basis, or for direct marketing purposes, or for scientific, historical, or statistical research purposes.
- Right to request deletion - You have the right to request that we delete, destroy, or anonymize your personal data when it is no longer necessary or there is no legal right to retain such personal data.
- Right to request suspension - You have the right to request that we suspend the use of your personal data while the accuracy of your personal data is being verified, or while we are considering your object request, or in case where you request us to suspend the use of your personal data instead of deleting or destroying it.
- Right to request correction - You have the right to request that we ensure your personal data is accurate, up-to-date, complete, and not misleading.
- Right to lodge a complaint - You have the right to file a complaint with the Personal Data Protection Committee or the Office of the Personal Data Protection Committee if we fail to comply with the law on personal data protection.
If you wish to exercise your rights regarding your personal data, you can contact us through the channels provided at the bottom of this policy. After verifying your identity, we will respond to your request within a reasonable and lawful timeframe. However, if we are authorized by applicable law, we may not be able to process your request in the following cases:
- The disclosure of information is likely to endanger the life, body, property, rights, or other interests of you or others.
- The disclosure of information is likely to interfere with our normal business operations.
- The disclosure of information would violate other laws and regulations.
- When you are unable to verify your identity according to your requested for disclosure of your information, or
- We are permitted under applicable law to refuse your request.
In some cases, you may incur costs in exercising your rights in accordance with our other procedures and policies, unless otherwise provided by law.
6. Changes to this Privacy Policy
We may revise, change, or amend this privacy policy in the future as deemed appropriate and in line with changes to our operations, or to comply with changes in legal requirements.
7. Contact Us
If you have any questions or wish to exercise any rights under the law or this policy, please contact us at:
Office: LTMH Public Company Limited
518/5 Maneeya Center Building, 7th Floor, Ploenchit Road
Lumpini, Pathumwan, Bangkok 10330