Privacy Notice on the Use of Closed-Circuit Television (CCTV)

Chaithanin Company Limited.

This Privacy Notice (“Policy”) describes the use of Closed-Circuit Television (“CCTV”) equipment at Chaithanin Company Limited (hereinafter referred to as the “company,” “we,” “us,” or “our”). The company utilizes CCTV equipment in conjunction with various systems for surveillance within designated areas, including the surrounding premises, buildings, and any other areas for the protection of life, health, and property. This involves the processing of personal data of employees, company directors, partners, workers, visitors, or any other individuals (collectively referred to as “you” or “your”) who are present within the surveillance areas of the buildings and premises. Furthermore, this Policy outlines our methods for collecting, using, disclosing, and transferring data relating to individuals that enables their identification (“Personal Data”). It also specifies the methods for managing and operating our CCTV system. We may amend this Policy at any time and will notify you of such amendments to the extent practicable.

1.Types of Personal Data We Collect

We collect moving or still images that can identify you, your voice, and your belongings, such as vehicles, when you enter the monitored areas within our premises, buildings, and any other designated areas, through our CCTV systems and devices (“CCTV Data”).

2.Purposes of Collecting, Using, or Disclosing Your Personal Data

2.1 We may collect, capture, use, disclose, transfer, and process, including but not limited to recording, storing, modifying, altering, adapting, destroying, erasing, retrieving, combining, copying, transmitting, retaining, withdrawing, updating, and adding to CCTV Data concerning you and other Personal Data related to you for the “CCTV Surveillance Purposes” listed below. This will be conducted on the legal bases of legitimate interest, for the protection of life, for legal compliance, for the public interest, based on consent obtained, or on any other basis permitted by applicable law in Thailand (provided that such interests do not override the rights and interests of any individual), which may be considered in the following cases:

2.1.1 To protect your life, body, personal health and safety, and/or personal property.

2.1.2 To control building access and maintain the security of the building, personnel, employees, and visitors, as well as our assets and information located or stored at that location.

2.1.3 To protect our premises, buildings, areas, and assets from damage, disruption, destruction, and other crimes.

2.1.4 To assist in the effective resolution of disputes that arise during disciplinary actions or the consideration of grievances.

2.1.5 To assist in the investigation or processing of complaints and reports.

2.1.6 To be used as evidence or rebuttal in civil proceedings, including but not limited to labor court proceedings.

2.1.7 To comply with our legal obligations and/or cooperate with courts, regulatory bodies, government agencies, and law enforcement agencies in the exercise of their legal authority, including but not limited to safety, occupational health, and workplace environment. We consider the use of CCTV systems to be a necessary measure to enable us to fulfill these obligations.

2.1.8 To exercise our rights or protect our legitimate interests where necessary to do so, to deter, prevent and detect misconduct, crime or legal violations, monitor events, to prevent and report misconduct or crime in our stores and to protect the safety and security of our business. We will continuously strive to balance our legitimate interests and those of third parties with your fundamental rights and freedoms relating to the protection of CCTV data concerning you, as the case may be. We will endeavor to identify the necessary steps to achieve an appropriate balance.

2.2 We will install CCTV equipment at key locations within our premises, buildings, and areas, except for certain areas such as restrooms.

2.3 Our CCTV system operates 24 hours a day, monitored by our security personnel through the devices, except in cases of equipment/system malfunction and/or maintenance.

2.4 We will place appropriate signage in locations where the CCTV system is in use.

3.Disclosure of Personal Data to Third Parties

3.1 We will keep your Personal Data related to the CCTV system confidential and will only disclose or transfer such Personal Data to subsidiaries, affiliates, other carefully selected third parties now or in the future, licensees, joint venture partners, and/or service providers (which  may be located overseas) to achieve the CCTV Surveillance Purposes as outlined in this Policy.

3.2 Third parties to whom we may disclose CCTV Data and other Personal Data relating to you include disclosure to our affiliates (as part of our legitimate interests and the interests of our affiliates to achieve the CCTV Surveillance Purposes), government agencies, and/or regulatory bodies (to comply with legal obligations or to support or assist law enforcement agencies in the investigation and prosecution of civil or criminal matters), and third-party service providers (as part of our necessary steps to ensure that we provide for the protection of your personal health and safety and property). However, access to CCTV data may be accessed or disclosed only to the extent necessary to address events that fall under one of the purposes specified in this Section 3.2 or to respond to legal requests under Section 2.1.

4.Transferring Your Personal Data Abroad

We may disclose or transfer your Personal Data from the CCTV system (as part of the necessary steps for your health, personal safety, and property) to third-party service providers located outside of Thailand. Such disclosure or transfer will only occur with your consent or based on other legal grounds that compel us to act as permitted by law (to comply with the terms of a contract between us and another person for your benefit). The destination country may or may not have data protection standards similar to those in Thailand. However, we will ensure that any transfer of your Personal Data complies with applicable data protection laws before such transfer is carried out.

5.Security Measures

5.1 We will implement appropriate technical and administrative security measures to protect CCTV Data and Personal Data relating to you from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure.

5.2 We will review and update our security measures from time to time as necessary or with the development of relevant technologies to ensure that the security measures are effective, appropriate, and meet the minimum legal requirements as stipulated by the relevant government agencies.

6.Retention Period of Your Personal Data

We will retain your Personal Data obtained from the CCTV system in our system for 28 days from the date of data recording to achieve the CCTV Surveillance Purposes. If we are no longer permitted under applicable law to retain your Personal Data from the CCTV system, we will delete it from our systems and records. However, we may retain your Personal Data from the CCTV system for a longer period, for example, until the end of legal proceedings, or where there is a law requiring a longer retention period, or where certain CCTV data must be retained for the continuation of certain events or to respond to claims from individuals exercising their legal rights.

7.Your Rights Regarding Your Personal Data

Subject to the provisions of the law and relevant legal exceptions, you may have the right to request access to and/or obtain a copy, transfer, rectify, erase, destroy, or anonymize certain types of your Personal Data that we hold, and to restrict and/or object to certain activities that we carry out using your Personal Data. In cases where any of our processing is based on your consent, you may withdraw your consent, but this may result in us being unable to fully provide our services to you. You may have the right to request that we disclose how we obtained your Personal Data without your consent and may also lodge a complaint with the competent authority under applicable law. In the event that you require our department to forward CCTV data to others, or if you need to use the CCTV data yourself, you may need to provide evidence from a competent official or legal authority to take the CCTV data outside the premises.

8.Contact Information

If you have any questions or concerns, or wish to exercise your rights regarding CCTV data, please contact us at:

Data Controller Details

Company’s Name : Chaithanin Company Limited. Department: Compliance Officer

Address : 193/439 Moo 10, Nong Prue Subdistrict, Bang Lamung District, Chonburi Province 20150

Telephone : 0922508448

Business Days and Hours : Monday – Saturday, 09:00 – 18:00

Email : compliance@chaithanin.com

9.Changes to this Privacy Notice

The company may amend this Privacy Notice from time to time to reflect any changes related to the processing of Personal Data and in relation to data protection laws or other relevant laws. The company will announce any significant amendments through appropriate channels.

This Privacy Notice on the Use of Closed-Circuit Television (CCTV) is effective from 15 January 2023

Announced on 1 December 2022