Phuket Square Co., Ltd. [“The Company”] has provided the installation of CCTV inside and surrounding areas of the company to maintain security of the premises, properties, employees, directors, executives, customers, business partners, and visitors of the Company ["You"]. The company recognizes the importance of personal data protection and is committed to protecting personal data of the data subjects in accordance with the Personal Data Protection Act B.E. 2019. Therefore, the company has set up a “Privacy Policy for CCTV” to notify you details related to the collection, use, and disclosure of personal data [“Data Processing”] including your data subject right as follows.

The Company has provided the installation of CCTV in visible areas by placing signs warning that CCTV are in use at the entrances and exits including areas that the company deems appropriate that it is a point that needs to be monitored by collecting your personal information when you enter the areas as follows:


However, the company will not install CCTV in the areas that may unreasonably infringe on your basic rights such as Breakrooms, toilets, shower rooms, or rest premises for workers.

The Company collects your personal information under the following legal bases:
1) Legitimate Interest: For legitimate interests of the company without exceeding the extent that you can reasonably expect, which will not violate your fundamental rights or freedom of rights.
2) Legal Obligation: To perform duties as required by law such as criminal law, civil and commercial law, civil procedure law, criminal procedure law, etc.

The Company collects your personal information for the following purposes:
1) To protect your health and personal safety which includes your belongings.
2) To protect the buildings, facilities, and assets of the company from damages, obstructions, and destruction of property or other crimes
3) To support the agencies involved in law enforcement to deterrence, prevention, search and legal action.
4) To provide assistance in the dispute resolution process which occurs during a disciplinary or grievance process.
5) To provide assistance in the investigation process or the process for submitting complaints.
6) To provide assistance in the process of initiating or defending civil litigation. This includes , but is not limited to, legal proceedings related to employment.

The company will keep your personal information in the CCTV confidentially and will not disclose it except in cases where it is necessary for the company to be able to achieve the objectives of surveillance and observation as specified in this policy. The company may disclose information in CCTV to the following persons or juristic persons:
1) Relevant departments within the company who have roles and duties as necessary according to the objective by the person or team of the company will be allowed to access your personal information as necessary and appropriate, including having an appropriate process for accessing your personal information.
2) Agencies with authorities and duties as specified by law for assistance and support law enforcement or for conducting investigations or litigations.

The Company recognizes the importance of the security of your personal information to ensure that the company's personnels and third parties acting on behalf of the company have complied with the standard of personal data protection appropriately. This includes the duty to prevent personal data leak.

The company will retain your personal information carefully in accordance with technical measure and organizational measures to maintain appropriate security in data processing and to prevent violations of personal information. Therefore, the company has established policies, regulations, and criteria for protecting personal information including measures to prevent recipients of information from the company from collecting, using, and disclosing information other than the intended purpose or without authority or illegally. The company has periodically updated the said policies, regulations, and criteria as necessary and appropriate. In addition, executives, employees, contractors, agents, consultants, and recipients of information from the company have duty to maintain confidentiality of personal information according to confidentiality measure set out by the company, including agreements for data processing.

The company has review for improvement of the company's personal information security procedures and measures to keep them up-to-date and to obtain a level of personal information security which appropriate to the risk, and to ensure the confidentiality of personal information, its completeness, accuracy, and continued availability in data processing , including the measures in place to protect against loss and unauthorized collection, access, use, alteration, modification, or disclosure of personal information. The company will implement various measures to maintain the security of the company's personal information when processing all types of personal information , regardless of whether that data processing is in electronic form or non-electronic forms.

To achieve the purpose of surveillance by using CCTV equipment as specified in this policy, the company will retain your personal information which obtained from CCTV system in the company's system no longer than the necessary period or as necessary as specified by law. Except in some cases , the company may retain your personal information for a longer period such as the case where legal rights are exercised, disciplinary proceedings or court proceedings. In the event that the company has no longer needs to retain your personal information, the company will delete and destroy your personal information.

To achieve the purpose of surveillance by using CCTV equipment as specified in this policy , the company will retain your personal information on CCTV for a period of 60 days from the date of recording. After the said period has elapsed, the company will delete and destroy your personal information by the system automatically.

8.1 Right to Withdraw Consents: If you have given your consent for the company to collect, use and/or disclose your personal information (Whether it is the consent given before or after the enforcement of the Personal Data Protection Act) you have the right to withdraw your consent at any time throughout the period that your personal information is retained at the company. Unless there is a restriction on that right by law or there is a contract that benefits you.

However, withdrawing your consent may affect you from using various services or according to the contract. For your benefit, you are advised to study and inquire about the effects before withdrawal of your consent.

8.2 Right to Access Personal Data: You have the right to access your personal information and request for a copy of such personal information from the company, including requesting the company to disclose the acquisition of personal information in the company's possession. The company may deny your request if access and requesting a copy of personal information will affect your rights and the freedom of other people or the company must comply with the law or a court order to prohibit the disclosure of that personal information.

8.3 Right to Request for Personal Data Transfer: You have the right to request your personal information in cases where the company has prepared that personal information in a format that can be read or used by tools or devices that work automatically and have the right to request the company to send or transfer personal information in such form to another data controller , including the right to request personal information that the company sent or transferred in such form to other data controllers directly unless unable to proceed due to technical reasons.

However, your personal information above must be the personal information that you have given consent to the company to collect, use and/or disclose or it is personal information that the company needs to collect, use, and/or disclose in order that you will be able to use the company's services as intended which you are a contractual party with the company or for use in carrying out your request before using the company's services or is other personal information as specified by legal authorities.

8.4 Right to Object to Data Processing: You have the right to object to the collection, use and/or disclosure of your personal information at any time if the collection, use and/or disclosure of your personal information is done for necessary operations under the company's legitimate interests or of another person or juristic persons without exceeding the extent that you can reasonably expect or for carrying out missions for the public benefit. If you submit an objection, the company will continue to collect, use and/or disclose your personal information only where the company can demonstrate legal grounds that it is more important than your basic rights or for the purpose of confirming legal rights, for complying with the law or defending against legal action on a case-by-case basis.

You also have the right to object to the collection, use and/or disclosure of your personal information for marketing purposes or for purposes related to scientific research history or statistics as well.

8.5 Right to Request Deletion of Personal Data: You have the right to request deletion or destruction of your personal information or making your personal information non- identifiable if you believe that your personal information has been collected, used and/or disclosed in violation of the applicable laws or when you consider the company has no longer needs to retain your personal information for the purposes related to this privacy policy or when you have exercised the right to withdraw consent or exercise the right to object as stated above , except in cases where the company must comply with the law or exercise legal rights related to the retention of such personal information.

8.6 Right to Request Suspension of Use of Personal Data: You have the right to request a temporary suspension of the use of your personal information in cases where the company is in the process of investigating your request to exercise your right to correct personal information or your objection or any other cases where the company has no longer needs and must delete or destroy your personal information in accordance with relevant laws but you request for suspension of use instead.

8.7 Right to Correct Personal Data: You have the right to request the company to correct your personal information to be accurate, up-to-date, complete, and not cause any misunderstandings.

8.8 Right to Complain: You have the right to file a complaint to the relevant legal authorities if you believe that the collection, use, and/or disclosure of your personal information is done in a manner that violates or does not comply with relevant laws.

If you have any queries about the company's practices regarding your personal information, please contact the company as specified in section 10 of this privacy policy. Where there are reasonable grounds to believe that the company has violated personal data protection laws, you have the right to file a complaint to the expert committee appointed by the Personal Data Protection Committee in accordance with the rules and procedures specified by the Personal Data Protection Act.

In the event that you submit a request to exercise your rights under the Personal Data Protection Act, it will be carried out within the time specified by law when the company has received the said request, and the company has the sole right and discretion to respond to your request or reject your request. In this regard, the company reserves the right to refuse or not proceed with such requests in cases required by law such as for compliance with the law and court order, public benefit, exercising your rights may violate the rights or freedoms of other people, etc. If the company refuses the above request, you will be notified of the reason for refusal.

The company will consider and review the policy on a regular basis for compliance with relevant guidelines, laws, and regulations. You will be notified of any important changes along with the updated policy through appropriate channels. The company recommends periodical check for any changes to this policy.

Any queries about the collection, use and/or disclosure of personal information or the exercise of rights regarding your personal information according to this policy, please contact us as the details below:

You acknowledge and agree to this privacy policy which is subject to the enforcement and interpretation according to Thai law and Thai Courts have the authority to consider any disputes that may arise.