Privacy Notice For the Shareholders, Bondholders, and Representatives of such Persons

Privacy Notice

For the Shareholders, Bondholders, and Representatives of such Persons

Sansiri Public Company Limited, subsidiaries and/or joint venture (hereinafter referred to as “Sansiri” or “we”) has placed the great importance on protection of your personal data as our shareholder or bondholders, including the case where you are a proxy or authorized person of such person (hereinafter referred to as “Representative”), and, to ensure that we will provide a protection to and handle your personal data in consistency with the personal data protection laws, we therefore establish this Privacy Notice to notify you the details of personal data handling, whether collection, use, and disclosure (collectively referred to as “processing”) which may be done, as well as to notify you your rights on personal data and our contact channels.

1. Objectives of Collection, Use or Disclosure of Personal Data

Sansiri may collect, use, or disclose your personal data under the lawful basis for the following objectives.

No. Objectives Lawful Basis
1.

For the management of shareholders and bondholders registration, proxy, and others, both for the shareholders and bondholders which is to comply with the law relating to public company limited or laws relating to the securities and exchange or other relevant laws.

For complying with the law
(Legal Obligation)

2.

For the distribution of dividends to the shareholders or repayment of principal and/or interest to the bondholders.

For complying with the law
(Legal Obligation)

For the performance of a contract
(Contractual Basis)

3.

For applying to use the website or application which Sansiri provides to the bondholders and for using website or application in accordance with the specified terms of use.

For the performance of a contract
(Contractual Basis)

4.

For holding a meeting, attending a meeting of the shareholders/bondholders, and managing on the arrangement of such meeting, such as registration of the attendants, record of the resolution, and so on.

For legitimate interests
(Legitimate Interests)

5.

For recording the photograph, sound and/or video during the meeting for the purpose of publication of the meeting through Sansiri’s website or other communication channels of Sansiri or for the attendants to view afterwards, or for publication for the benefit of Sansiri or the attendants.

For legitimate interests
(Legitimate Interests)

6.

For recording the meeting and preparing the minutes of meeting to send to the relevant entities, such as the Securities and Exchange Commission of Thailand, legal consultants of Sansiri, shareholders, bondholders, including the publication of the details through Sansiri’s website or other communication channels of Sansiri.

For legitimate interests
(Legitimate Interests)

7.

For informing the news and information with respect to investor relations activities which is held for the shareholders and bondholders as Sansiri sees appropriate and for being the information for selection procedures of the activity participants.

For legitimate interests
(Legitimate Interests)

8.

For analyzing the information, preparing the activities, organizing the event and facilitating the shareholders and bondholders attending the activities held by Sansiri as Sansiri sees appropriate, such as preparing the place, preparing food and beverage or preparing the transportation, the souvenirs, and so on.  

For legitimate interests
(Legitimate Interests)

9.

For preparing the insurance or travel insurance (if any) in case you attend the activity held by Sansiri.

For legitimate interests
(Legitimate Interests)

10.

For concluding the database and proceeding with any operations regarding the provision of any benefits as you are a shareholder/bondholder of Sansiri, such as subscription right of the shares of group companies which are initial public offering, debenture subscription right, and so on.

For legitimate interests
(Legitimate Interests)

11.

For concluding the database of stakeholders of Sansiri and/or for relationship management or coordination relating to Sansiri, including opinion surveying for analyzing and improving the operation of Sansiri.

For legitimate interests
(Legitimate Interests)

12.

For conducting the risk management and internal control of the organization, supervision, inspection, as well as for the internal inspection of the Internal Audit Office and for good corporate governance, and internal management of the organization.

For legitimate interests
(Legitimate Interests)

13.

For establishing the legal claims, complying with or exercising the legal claims, or defending the legal claims, proceeding with lawsuit, as well as proceeding with legal execution

For legitimate interests
(Legitimate Interests)

14.

For complying with the law or an order of government agencies, independent entity, or competent authorities, such as to comply with the summons, an order of the court, the police officer, the public prosecutor, government agency, including a report or disclosure to the government agencies, or independent entities.

For complying with the law
(Legal Obligation)

15.

For managing relating to your sanitation and safety.

For preventing or suppressing a danger to the life, body, or health of the person
(Vital Interests)

The personal data which Sansiri collects for distribution of dividends to the shareholders, the payment of principal and/or interest for the bondholders, the management of shareholders and bondholders registration, and proxy are the information necessary to Sansiri for the performance of contract or the terms with respect to rights and obligations of the issuer and bondholders, and for compliance with various applicable laws, including for compliance with the laws relating to public company limited and laws relating to securities and exchange. In case you do not provide the necessary information, Sansiri may be unable to administer or manage the shareholder and bondholder contract between you and Sansiri, as well as the benefits you will obtain, as you are a shareholder or bondholder (if any).  

2. Personal Data Which Will Be Collected

Generally, Sansiri will collect your personal data by requesting such information directly from you, such as to request you to fill the information in a form specified by Sansiri or asking from you or requesting you to send the documents contained with your personal data to Sansiri. However, in some cases, Sansiri may collect your personal data from other sources for accomplishing the above-specified objectives, such as the securities registrar.

In this regard, Sansiri collects your personal data, as follows.

  • 2.1 General Personal Data
    1. Information enables the identification of a person (Identity Data), such as name, surname, national ID card number, passport number, date of birth, gender, age, nationality, signature, information regarding a change of name-surname, photograph.
    2. Contact information (Contact Data), such as address, telephone number, email.
    3. Financial information (Financial Data), such as bank account number (for receiving benefits in case of dividend payment, payment of principal and/or interest) number of shares/bonds (unit)
    4. Information with respect to communication with Sansiri (Communication Data), such as, video or audio recordings when contacting with Sansiri.
    5. Information with respect to participation in various activities of Sansiri, such as recording of still photos or video, and/or sounds.
    6. Information with respect to electronic accounts, such as name of user account (Username) Line ID.
    7. Other personal data, such as occupation, opinion, or recommendations, and so on.
  • 2.2 Sensitive Personal Data

    In general, Sansiri does not desire to collect and use the information pertaining to religious beliefs and blood type specified on your copy of national ID card for any objective in particular. In case you provide a copy of national ID card to Sansiri, please hide such information. In case you do not hide aforementioned information, it shall be considered that you give a consent to Sansiri to hide such information and it shall be considered that the document having such hidden information is valid and enforceable in accordance with the law in all respects. In this regard, if Sansiri is unable to hide the information due to some technical restriction, Sansiri will collect and use such information as only for a part of your identity verification.

    However, to process the personal data of shareholders and bondholders, there might be some activities which Sansiri will request some sensitive personal data additionally, such as when you participate in any activity for the shareholders and bondholders, Sansiri may request sensitive personal data, i.e., health data, and so on, for facilitating in arrangement of such activity or for other purposes which we will specifically notify in a consent form, and Sansiri will seek for your explicit consent prior to the collection of such sensitive personal data.

3. Retention Period

Sansiri will retain your personal data for the period as necessary for performing the objectives of collection, use or disclosure of the personal data specified herein. The criteria for determining the retention period are the period which Sansiri still needs to use your personal data in accordance with the objectives and may continue to retain as the period necessary for complying with the laws, or legal prescription, or for the establishment, compliance or exercise of legal claims, or defense of legal claims, or for other cases according to the policy and internal regulations of Sansiri.

4. Disclosure of Personal Data

For performing the objectives specified in this notice, Sansiri may disclose your personal data to the following third parties.

  • 4.1 Subsidiaries, affiliated companies, and group companies of Sansiri for the purpose of accomplishment of above specified objectives.
  • 4.2 Government sectors, supervisory authorities, or other entities prescribed by laws, including the competent officials, such as the court, the police officers, the Securities and Exchange Commission of Thailand, and the Revenue Department.
  • 4.3 Agents, contractor/subcontractor and/or service provider performing any operation, such as the service provider who organizes the activities and facilitates the shareholders/bondholders, auditor, lawyer, legal consultant, financial institute appointed as a financial consultant or bond underwriter.
  • 4.4 Insurance companies and/or agent/broker of insurance/life insurance which provide insurance services or travel insurance service to the shareholder or bondholder or representative of the shareholder or bondholder in case travel insurance shall be provided to the participants of Sansiri’s activities.
  • 4.5 A bank having a duty to proceed with a payment to the shareholder/bondholder.
  • 4.6 Registrar of the shareholder/bondholder.
  • 4.7 Representative of the bondholders.
  • 4.8 Hospital or sanatorium.

5. Transfer or Disclosure of Personal Data to Other Countries

Sansiri may store your personal data in the computers, servers, or clouds of service providers located in other countries, and may process information by using package software or application of service providers located in other countries.

In this regard, to send or transfer your personal data to other countries, for any case, Sansiri will comply with the Personal Data Protection Act, B.E.2562 (2019).

6. Your Rights as a Data Subject

As you are a data subject, you have the rights as prescribed by the Personal Data Protection Act, B.E.2562 (2019). In this regard, you can exercise your various rights through the channels which Sansiri specifies in Clause 9 or through Sansiri’s website. You are entitled to exercise the rights when the personal data protection law is enforced. Your rights are as follows.

  • 6.1  Right to withdraw the consent (Right to Withdraw Consent) 

    In case Sansiri requests for your consent, you are entitled to withdraw the consent for processing of personal data given to Sansiri, unless such withdrawal of consent is restricted by law or contract which is beneficial for you.

    In this regard, the withdrawal of consent shall not affect any processing of personal data which the consent was already legally given by you.

  • 6.2 Right to access to the personal data (Right to Access) 
    You are entitled to request for accessing and obtaining a copy of your personal data, which is under responsibility of Sansiri, including request Sansiri to disclose the acquisition of such information which you do not consent to Sansiri.
  • 6.3 Right to request for sending or transferring of personal data (Data Portability Right)  
    You are entitled to request Sansiri to transfer your personal data provided to Sansiri in accordance with the laws.
  • 6.4 Right to object the collection, use or disclosure of personal data (Right to Object) 
    You are entitled to object to the processing of information relating to you for the collection, use or disclosure of personal data that is prescribed by law.
  • 6.5 Right to erase the personal data (Erasure Right)  
    You are entitled to request Sansiri to erase your personal data as prescribed by law. However, Sansiri may collect your personal data by electronic system which some of the system may be unable to be erased. In such case, Sansiri will destroy or anonymize such personal data to become anonymous data that cannot identify you.
  • 6.6 Right to request for restriction of the use of personal data (Right to Restrict Processing) 
    You are entitled to request Sansiri to restrict the use of your personal data as prescribed by law.
  • 6.7 Right to request for correcting the personal data (Rectification Right) 
    In case you opine that the information possessed by Sansiri is incorrect or you have changed your personal data, you are entitled to request Sansiri to correct your personal data so that your such personal data will be accurate, up-to-date, complete, and not misleading.
  • 6.8 Right to lodge a complaint (Right to Lodge a Complaint)  

    You are entitled to lodge a complaint to the competent authority in accordance with the Personal Data Protection Act, B.E.2562 (2019) in the event that Sansiri violates or does not comply with such Act.

    In case the data subject filed a request for exercising of rights under the provisions of the Personal Data Protection Act, B.E.2562 (2019), upon receipt of such request, Sansiri will proceed with such request within the period specified by law. Anyway, Sansiri reserves the right to reject or non-comply with such request for the case where it is prescribed by law.

    You can proceed with the exercise of above specified rights by notifying through the Call Centre, telephone no.1685 which you will be required to file the request for exercising the right of data subject (download), including verify your identity for exercising such rights in accordance with the methods and procedures specified by the Company. In this regard, the Company will consider and inform you of the result of consideration of your request within 30 days from the date which the Company received such request.

7. Amendment of this Notice

We may occasionally amend this Privacy Notice and, if there is such amendment, we will announce it on Sansiri’s website and/or invitation letter of the annual general meeting of the shareholders and/or news channels of the Stock Exchange of Thailand and/or notify you through email. In this regard, in case it is necessary to request your consent, we will proceed with requesting the consent from you additionally.

8. Contact Methods

If you have any questions or would like to ask for more information regarding the protection of your personal data, the collection, use or disclosure of your personal data, the exercise of your rights, or any complaints, you can contact Sansiri at the following channels.

Sansiri Public Company Limited 
Data Protection Officer

Contact place: 59 Soi Rim Khlong Phra Khanong, Phra Khanong Nuea Sub-district, Vadhana District, Bangkok 10110
Telephone no.: 1685
Email: cs@sansiri.com