Privacy Policy
All Seasons Property Co., Ltd. and Affiliated Companies
Published on 30 May 2022
All Seasons Property Co., Ltd. and its affiliated companies (“All Seasons Place”) is an office space and retail business space provider that adheres to ethical business conducts and compliance with applicable legal standpoint. All Seasons Place is aware of the importance of the protection of Personal Data of the persons in contact and/or doing business with All Seasons Place, for instance, customers, contract parties, business partners, contractors, service providers, job applicants, employees (“You” or “Your”). Therefore, All Seasons Place hereby announces this Privacy Policy (“Policy”) to prescribe the direction and processes All Seasons Place undertakes pertaining to your Personal Data, for instance, to collect, retain, use or disclose such data with high standard and strict processes in order to safeguard your Personal Data from unauthorized access, use, modification or disclosure, and to assure that such processes shall uphold your rights under the Personal Data Protection Act B.E. 2562 (“PDPA”).
All Seasons Place suggests that you carefully read this Policy prior to giving Personal Data to All Seasons Place in accordance with the purposes prescribed in this Policy so that you recognize and understand this Policy and your rights and protections under PDPA as follows.
All Seasons Place may review or amend this Policy from time to time in order to comply with PDPA and/or subordinate legislations, regulations, announcements of any government authority which will be newly issued. If there is any amendment of this Policy, All Seasons Place will publish the updated version on All Seasons Place’s website and/or other communication channels.
1. Purposes of this Policy
This Policy is to inform you, as the owner of Personal Data (“Data Subject”, “you” or “your”), to be aware of the purposes and details of the collection, storage, use and/or disclosure of your Personal Data as well as your legal rights and protection in connection with Personal Data.
2. Definition of Personal Data
2.1 “Personal Data” means any information pertaining to a natural person (Data Subject), which enables the identification of such Data Subject, whether directly or indirectly (excluding data of a deceased), including:
2.1.1 Personal data that you give directly to All Seasons Place, or available to All Seasons Place through your lease, obtaining of services, contact, visits, or any legal relations with All Seasons Place; and
2.1.2 Personal data received or accessible by All Seasons Place through other sources, for instance, government agencies, affiliated companies of All Seasons Place, business partners, and information service providers. All Seasons Place shall collect and retain such Personal Data only upon receiving your legal consent unless where necessary and permissible under PDPA or other applicable laws.
2.2 Personal Data can be classified into two categories:
2.2.1 General Personal Data comprising:
(a) Personal information, such as title, first name, surname, nickname, gender, age, nationality, date of birth, place of birth, weight, height, signature, photo, voice, recorded voice, marital status, number of family members, information of family members, personal history, educational record, occupation, job position, workplace, type of business, information provided in any document issued by government authorities, for instance, national identification card, household registration, marriage registration, first name-surname change registration certificate, passport, VISA, alien registration card, driver’s license, car registration, social security, tax registration and other information or documents used for person identification, details of immigration such as date of arrival and departure and/or other personal information which Data Subject has provided to All Seasons Place;
(b) Contact information, such as domicile, address, e-mail, telephone number, username and password, or social media accounts, such as LINE, Facebook, Instagram, Google, and/or other contact information which Data Subject has provided to All Seasons Place;
(c) Financial information, such as information related to payment transaction, credit bureau, bank information, for instance, details related to bank account, or other financial status, and other financial information of tenants, including information related to payment transaction, credit card information of visitors related to payment to All Seasons Place (i.e., car parking fee);
(d) Technical information, such as
(1) cookie information and other information from your browsing website or application of electronic device which All Seasons Place has received or recorded from the browser or your electronic devices; and
(2) other technical information derived from the use of platform, operating systems, or any other online channels of All Seasons Place and/or its business partners.
(e) Marketing and communication information, such as a request or subscription of receiving any information or marketing news from All Seasons Place and/or its business partners including relevant details;
(f) Other information, such as Audio/Visual Recording Information obtained when you contact All Seasons Place at the premises or through your transactions via Video Call or Help Desk of All Seasons Place;
(g) Any other information deemed as Personal Data under PDPA.
2.2.2 Sensitive Data, such as race, ethnic group, religion, political opinion, body or mind conditions, disability, health information, medical record, blood type, credit information, criminal record, biometric information using the technics or technology related to the physical or behavioral dominance of a person, which can be used to identify such person, such as, fingerprint, iris recognition data, facial or voice recognition data. All Seasons Place shall not collect sensitive data unless receiving prior consent from Data Subject for the purposes of
(a) authentication of your identity when obtaining services and/or doing transaction with All Seasons Place provided that you agree to use biometric information for this purpose and/or
(b) using as your electronic signature when doing transactions with All Seasons Place through online / digital channel, or website of All Seasons Place.
3. No Consent Required: Purposes of Collection, Use and/or Disclosure of Personal Data
All Seasons Place shall request consent from you before or while collecting Personal Data through electronic or any other means except for the following purposes which All Seasons Place can proceed by relying on other legal grounds to do so, without first obtaining your consent, but merely informing you of the purposes to collect, retain, use and/or disclose Personal Data:
3.1 for the performance of a contract entered between you (as tenants, suppliers, service providers, contractors or others) and All Seasons Place such as sale and purchase of goods and work for hire, and use of All Seasons Place’s services such as product delivery, or other services, or online services through a platform;
3.2 for compliance with applicable laws;
3.3 for your interest, and the consent cannot be obtained at that time;
3.4 for the necessity purpose to prevent or suppress any danger to a person’s life, body or health;
3.5 for making documents for public interest or for study, research, statistical purposes under appropriate protection measures;
3.6 for necessity purpose under legitimate interests of All Seasons Place or other person or juristic person:
3.6.1 Implementing a preventive plan or measures to minimize risks arising from frauds, cyber threat or violations of laws;
3.6.2 Recording videos of visitors making transactions at the offices or areas under surveillance of All Seasons Place onto CCTV or verifying your identity, without applying biometric information using the technics or technology related to the physical or behavioral dominance of a person, or communicating and sharing Personal Data within All Seasons Place and its affiliated companies for security purpose within the retail center, residence and office buildings of All Seasons Place;
3.6.3 Risk management, compliance, audit, examination or investigation of frauds or unlawful acts or suspicious transactions;
3.6.4 Internal management including sharing of Personal Data within All Seasons Place;
3.6.5 Compliance with legal claims or execution of All Seasons Place’s legal rights such as debt collection, litigation, police journal entry, or police report filing;
3.6.6 Monitoring of e-mail correspondence or internet transaction between All Seasons Place’s employees and you to prevent leakage of All Seasons Place’s confidential information.
4. Consent Required: Purposes of Collection, Use and/or Disclosure of Personal Data
All Seasons Place shall collect your Personal Data in accordance with your consent for the main purposes of selling products and/or providing services to you or assisting you in doing transactions and/or using the services you desire including for the following purposes.
If you decline to provide Personal Data to All Seasons Place, you may not receive the services or experience inconvenience, or All Seasons Place may not be able to perform contractual obligations in the contract with you in which you may suffer, or loss of opportunity.
4.1 Advertisement and public relations of businesses or services of All Seasons Place and/or its business partners;
4.2 Communicating or conducting public relations within All Seasons Place;
4.3 Managing business of All Seasons Place or which All Seasons Place hires or assigns others to proceed on its behalf;
4.4 Recruitment, and employment of personnel or employees of All Seasons Place;
4.5 Sharing, transferring or disclosing information to business partners of All Seasons Place or other third party to which All Seasons Place is a party or having relationship with, both in Thailand and overseas, and any other persons which you will be further notified for the purposes of providing services to you or enabling you to do transactions and/or use the services you desire and/or for other purposes specified in Clauses 4.1- 4.4, where the examples of a third party that All Seasons Place will disclose information are specified in Clause 5 hereof.
You agree that your consent given under this Policy will be valid for a period of 10 (ten) years from the date that you stop being a tenant, or terminate the relationship, or do transaction, or last contact with All Seasons Place, whichever occurs later. You can withdraw this consent at any time by contacting All Seasons Place through contact channels specified herein.
5. Disclosure of Personal Data
All Seasons Place shall not share or disclose your Personal Data to any third party unless (i) All Seasons Place has obtained your consent (ii) it is for the following purposes prescribed in this Policy (iii) it is to comply with the law or order of government agency, or any other law enforcement agencies. All Seasons Place may be required to disclose your Personal Data to the following third party (located in Thailand and overseas):
5.1 External service provider to carry out relevant operations related to All Seasons Place’s business which shall include, without limitation, manufacturer, service provider, retail operator, event organizer, marketing, research, opinion survey, data analysis, IT service provider, data storage and cloud service provider, risk management, telecommunication, bank and financial institution, investment, life-insurance, non-life insurance, warehouse management and control, logistics, courier service provider, transportation, shipping, maintenance service, system engineering, construction, postal service, electronic procurement system, e-commerce, e-payment, call center, medical service, marketing and advertising media, digital multimedia, touring, printing, personnel outsourcing, brokerage service and debt collection, etc.;
5.2 All Seasons Place’s business partners who participate in promotional or marketing activities or jointly provide or offer products or services to you, or assist you to do transactions and/or use services you desire, including collaboration to invent, develop or improve products or services to meet the needs and maximize satisfaction for you or the customers of All Seasons Place;
5.3 Advisers such as legal advisors, financial advisors, or specialists or external auditors,
5.4 Assignee of rights and/or obligations in case of merger and acquisition, or transfer of business, in whole or in part, to any third party,
5.5 Government authorities and/or state agencies such as the Revenue Department, Office of Trade Competition Commission, etc. including court, Office of the Attorney General, Royal Thai Police or any other law enforcement agencies.
In disclosing your Personal Data to a third party above, All Seasons Place will limit the disclosure of your Personal Data only to the extent as required to achieve the relevant purposes, and will procure such third party to sign a Personal Data Processing Agreement to ensure that such third party will not use your Personal Data for any other purposes, and will strictly keep your Personal Data secure as required by laws.
6. Transfer of Your Personal Data to a Foreign Country
All Seasons Place may disclose or transfer your Personal Data to other countries, a third party or a server located overseas where such destination country may or may not have the same data protection standards. Provided that, All Seasons Place will proceed with procedures and measures to ensure that your Personal Data will be securely transferred, and that the person who receives your Personal Data has in place appropriate data protection standards or other derogations as permitted by laws. All Seasons Place will request your consent if it is required by applicable laws for transferring Personal Data to overseas.
7. Rights of Data Subject
All Seasons Place is aware of your personal rights which are under protection of PDPA in which you are entitled to exercise those rights at any time by sending a request to All Seasons Place’s Data Protection Officer (“Company DPO”) via contact channels indicated herein.
In case you are under 20 years old or your legal capacity is restricted, your father, mother, guardian or representative is required to exercise the rights on your behalf.
All Seasons Place will strictly proceed in accordance with your request pertaining to the rights of Data Subject under PDPA within 14 (fourteen) business days upon receipt of such request as follows.
7.1 Rights to Withdraw Consent
You have the rights, at any time, to withdraw the consent given to All Seasons Place for collection, use and/or disclosure of your Personal data except that such rights is restricted under applicable laws or contract which benefits you.
7.2 Rights to Access Information
You have the rights to request for accessing and receiving copy of your Personal Data which is in possession of All Seasons Place or request All Seasons Place to disclose acquisition of such Personal Data for which you have not given your consent.
7.3 Rights to Data Portability
You have the rights to request your Personal Data from All Seasons Place in the event that All Seasons Place has made such Personal Data in readable format or usable by any automatic equipment or device and capable of using or disclosing automatically including (a) rights to request All Seasons Place to send or transfer your Personal Data to another data controller when capable of doing so automatically or (b) rights to receive Personal Data in which All Seasons Place sends or transfers in such format to another data controller directly unless it is impossible to do so due to technical limit.
7.4 Rights to Object Collection, Use or Disclosure of Personal Data
You have the rights to object collection, use or disclosure of your Personal Data for Personal Data collected under the necessity for the performance of a task carried out in the public interest by All Seasons Place or the necessity for legitimate interest of All Seasons Place or other persons, provided that, All Seasons Place may reject your rights in case All Seasons Place is able to justify greater importance of its legitimate interest, or establishing legal claim, complying with the law, or exercising or defending legal claims;
Nevertheless, All Seasons Place may reject your request specified in this Clause 7.4 if the retention of Personal Data is for following purposes:
(a) For the purpose of exercising freedom of expression;
(b) For the achievement of the purposes relating to the preparation of documents for public interest, or for the purposes relating to research or statistics, in which the suitable measures to safeguard your rights and freedoms are put in place;
(c) It is necessary for the performance of a task carried out in the public interest by All Seasons Place, or it is necessary for the exercising of official authority vested in All Seasons Place;
(d) It is necessary for compliance with the law to achieve the purposes with respect to: (i) preventive medicine or occupational medicine, the assessment of working capacity of the employee, medical diagnosis, the provision of health or social care, medical treatment, management of health or social care systems and services, or (ii) public interest in public health;
(e) For the purpose of establishing, or exercising, or defending legal claims, or complying with the law.
7.5 Rights to Erasure/Rights to be forgotten
You have the rights to request All Seasons Place to erase or destroy or anonymize your Personal Data in the following events:
7.5.1 When the Personal Data is unnecessary for retention in accordance with the purpose of collection, use or disclosure;
7.5.2 When you as Data Subject have withdrawn the consent for collection, use or disclosure of Personal Data and All Seasons Place no longer has legitimate rights to collect, use or disclose such Personal Data;
7.5.3 When Personal Data is collected, used or disclosed unlawfully.
7.6 Rights to Restrict Processing of Personal Data
You have the rights to restrict the use of your Personal Data by All Seasons Place in the following events:
7.6.1 During the investigation by All Seasons Place pursuant to your request specified in Clause 7.7;
7.6.2 Personal data which must be erased or destroyed because it was unlawfully collected/used or disclosed but you request to restrict the use instead;
7.6.3 When Personal Data is no longer required to be retained in accordance with the purpose of collection of such Personal Data. However, it must be retained due to your necessity for establishing legal claim, complying with laws, or exercising or defending legal claims;
7.6.4 When you have exercised your rights to object collection, use, or disclosure of your Personal Data specified in Clause 7.4 and All Seasons Place is proving of its legitimate interest with greater importance than your rights, or establishing legal claim, complying with laws, or exercising or defending legal claims pursuant to Clause 7.4, paragraph one (a); or All Seasons Place is proving of its task carried out in the public interest pursuant to Clause 7.4, paragraph one (c).
7.7 Rights to Rectification of Personal Data
You have the rights to request All Seasons Place to amend your Personal Data so that it is up-to-date, correct and not misleading.
7.8 Rights to Complain
You have the rights to file a complaint to the expert committee under Personal Data Protection Committee if All Seasons Place or any data processor or any of employees or contractors of All Seasons Place or data processor are in breach of PDPA and/or any ministerial regulations or announcement issued under PDPA.
8. Your Procedure to Give Personal Data
All Seasons Place shall be able to provide services of your interest or perform its obligation under the contract upon receiving your Personal Data which is correct and required for the relevant purposes including to verify and ensure that the collection, use, or disclosure of your Personal Data which is proceeded by All Seasons Place shall be in compliance with Customer Due Diligence criteria and your Personal Data is correct and up to date. Thus, your cooperation in giving Personal Data to All Seasons Place is required.
9. Retention Period of Personal Data
All Seasons Place will retain your Personal Data for as long as is necessary during the period that you are using the services of, or have relationship with All Seasons Place, or for as long as is necessary to fulfil the purposes prescribed in this Policy. If you cease to be tenant of All Seasons Place or have terminated relationship with All Seasons Place, All Seasons Place shall retain your Personal Data for back-up purpose as required by applicable laws and/or in accordance with the policies or standard operating procedures on data retention and destruction of All Seasons Place. All Seasons Place will erase, destroy, or anonymize Personal Data when it is no longer necessary or when the period lapses, provided, however, within 10 (ten) years from the date that you stop being tenant, or terminate the relationship, or do transaction, or last contact with All Seasons Place, whichever occurs later.
10. Data Protection Officer
All Seasons Place has appointed the Data Protection Officer (“Company DPO”) to monitor the compliance of All Seasons Place in accordance with PDPA and this Policy, to coordinate with you in handling the complaints, and to facilitate your request to exercise the rights under PDPA.
If you have any comments or questions or inquiries regarding the collection, use and/or disclosure of your Personal Data and your rights under PDPA or wish to withdraw or cancel your consent or cease receiving information or if you are aware of any breach of your Personal Data, please contact All Seasons Place through the following channels:
Email : DPO@ASP.TH.COM
Contact : Legal
19th floor, M. Thai Tower, 87, Wireless Road, Lumpini Subdistrict, Pathumwan District, Bangkok 10330