This privacy policy (this “Privacy Policy”) on the use of closed-circuit television (“CCTV”) devices describes how PURI Company Limited and/or its affiliates (referred to as “PAÑPURI”, “we”, “us”, or “our”) use CCTV devices and its system for monitoring our specific space within and around our premises, buildings and facilities for protecting life, health, and property, of personal data of all employees, directors, contractors, workers, visitors, or any individuals entering the monitored space within our buildings and facilities (collectively referred to as “you” or “your”). This Privacy Policy also describes how we collect, use, disclose and transfer of individually identifiable information (“Personal Data”) about you and set out how the CCTV and its system will be managed and used by us. We may amend this Privacy Policy at any time and will notify you of the amendments, where possible.

1. What Personal Data we collect

We capture your recognizable moving or still images, voice of you and your belongings e.g. vehicles, when entering the monitored space in our premises, buildings and facilities through the CCTV devices and system (“CCTV Data”).

2. Why we collect, use, and disclose your Personal Data

2.1 We may collect, capture, use, disclose, transfer, and carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, adding, in relation to your CCTV Data and other Personal Data concerning you, for the “CCTV Monitoring Purposes” as listed below, on the legal basis of legitimate interests; vital interest; legal compliance; public interest; consent; or any other basis as permitted by applicable laws (provided that those interests are not overridden by individuals’ rights and interests), as the case may be:

• to protect your life, body, health personal safety, and/or your belongings;
• to control access to building and to ensure the security of the building, the safety of our personnel, employees and visitors, as well as our property and information located or stored on the premises.
• to protect/prevent our premises, buildings, facilities and assets from damage, disruption, vandalism and other crime;
• to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
• to assist in the investigation or proceedings concerning a whistleblowing complaint;
• to assist in the establishment or defense of any civil litigation, including but not limited to employment proceedings;
• to comply with our legal obligations and/or cooperate with court, regulators, government authority and law enforcement bodies for the exercising of such official authority vested in us including but not limited to safety, occupational and workplace environment laws. We consider that use of CCTV is a necessary measure to enable us to meet those obligations; and
• to exercise our rights or protect our legitimate interest where it is necessary to do so, for example to deter, prevent, and detect of misconduct, crime or violations of law; to follow up on incidents; to prevent and report misconduct or crime in our stores and to protect the security and integrity of our business. We will endeavor on the continuing basis to balance between our legitimate interest and that of any relevant third parties, as the case maybe, and your fundamental rights and freedom in relation to the protection of the CCTV Data concerning you. We will also endeavor to identify any steps required to achieve the right balance as appropriate.

2.2 We will install CCTV devices at strategic points within our premises, buildings and facilities, except certain areas such as onsen, treatment room, changing rooms, toilets, and shower rooms.

2.3 Our CCTV devices are in operation 24 hours a day, except in case of device/system failure and/or maintenance.

2.4 We will place appropriate signage in the monitored areas that the CCTV is in use.

3. To whom we disclose your Personal Data

3.1 We will keep CCTV Data concerning you confidential, and will not disclose or transfer it except to our subsidiaries, affiliates, and other carefully selected third parties now or in the future, licensees, joint venture partners and/or service providers, [who may be located overseas,] to achieve the CCTV Monitoring Purposes provided in this Privacy Policy.

3.2 Third parties to which we may disclose CCTV Data and other Personal Data concerning you include our affiliates (as part of our legitimate interest and our affiliates’ interest to achieve the CCTV Monitoring Purposes), governmental and/or regulatory organizations (to comply with legal obligations or to support or assist law enforcement organizations with regard to investigation and prosecution of civil or criminal proceedings), and third-party service providers (as our necessary steps to ensure our protection of your health and personal safety, and belongings). However, the access to CCTV Data may only be accessed or disclosed to the extent necessary in order to deal with an incident which falls within one of the objectives identified in this Clause 3.2 or in order to respond a request made by an individual under the law under Clause 2.1.

4. Transfer your Personal Data internationally

We may disclose or transfer your CCTV Data as part of necessary steps to ensure your health, personal safety, and belongings, to our third-party service providers that are outside of Thailand, and such disclosure or transfer may only be done by obtaining your consent or there are any other compelling legitimate grounds (e.g. to perform the contract terms between us and other persons for your benefit) as permitted by applicable laws. Such destination countries may or may not have the same data protection standard similar to Thailand, however, we will ensure that the data transfer requirement under applicable data protection law which is in effect at that time is met before such transfer.

5. Security measures

5.1 We use reasonable organizational, technical and administrative security measures to protect CCTV Data and Personal Data concerning you from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure.

5.2 We will from time to time review and update our security measures as necessary or upon development of the concerning technology to ensure effective and appropriate security measures, and in line with minimum legal requirements as prescribed by the relevant governmental organizations.

6. How long de we retain your Personal Data

We will retain your CCTV Data in our system for the period necessary to fulfill the CCTV Monitoring Purposes for which we obtained them. When we are no longer permitted by the applicable laws to store your CCTV Data, we will remove it from our systems and records. However, we may retain your CCTV Data for a longer duration, such as until the end of legal action or if required by the applicable laws or specific CCTV Data are required to be retained in order to deal with an incident or in order to respond to a request by an individual made under the law.

7. What are your rights with regards to your Personal Data

Subject to the conditions and exceptions under the applicable laws, you may have the rights to access and/or obtain a copy of, port, rectify, delete, destroy or anonymize certain CCTV Data that we have about you, restrict and/or object to certain activities, in which we engage with respect to your personal data. If we process your Personal Data based on your consent, you may withdraw your consent, but we may not be able to provide you with our goods or services. You may also have the right to request us to disclose how we obtain your Personal Data without your consent and lodge a complaint with the competent authority under the applicable laws.

8. Contact us

If you have questions or concerns or would like to exercise your rights in relation to your CCTV Data, please contact us or our Data Protection Officer at:

1) Company Name
PURI Company Limited
29 Vanissa Building, 20th Floor, Unit C, Tower B, Soi Chidlom, Ploenchit Road, Lumpini, Pathumwan, Bangkok 10400, Thailand
+66 (0) 2-253-5858
info@panpuri.com

2) Data Protection Officer
Data Protection Officer
29 Vanissa Building, 20th Floor, Unit C, Tower B, Soi Chidlom, Ploenchit Road, Lumpini, Pathumwan, Bangkok 10400 Thailand
dpo@panpuri.com