Last modified on 29 September 2023
Tencent (Thailand) Company Limited (hereinafter referred to as “Tencent” or “We”) places great importance on protecting the Personal Data of employees, staffs and family members (hereinafter referred to as “you”) We want to assure you that we will protect and handle your personal data in compliance with the Personal Data Protection Act B.E. 2562 (hereinafter referred to as “Personal Data Protection Law”). We have established this Privacy Policy to explain how we use the Personal Data we receive from you and to inform you of your rights as the Data Subject. To ensure that you have a comprehensive understanding of the details as stipulated by the Personal Data Protection Law, Tencent recommends that you carefully read and understand the various provisions under this Privacy Policy in detail.
Tencent (Thailand) Company Limited’s affiliated companies refer to one or more legal entities, including but not limited to:
- Tencent Online (Thailand) Ltd.
- Webspace Ltd.
- MWEB Portal (Thailand) Ltd.
- Levelup Online Co., Ltd.
- Topspace (Thailand) Co., Ltd.
- WeChat (Thailand) Co., Ltd.
1. Definition
| Personal Data | Information that enables the direct or indirect identification of an individual but excludes data concerning the deceased person |
| Data Controller | Tencent, as an entity with decision-making authority, determines the collection, use, or disclosure of personal data |
| Data Subject | Individuals who are data subjects include employees, staffs and family members (hereinafter referred to as “you”) |
| Data Processor | Individuals or legal entities who process, use, or disclose Personal Data on the orders or on behalf of Tencent |
| Individual | Natural person |
| Sensitive Data |
Personal Data that is inherently sensitive and may pose a risk of unfair discrimination includes, but is not limited to, race, ethnicity, political opinions, religious or philosophical beliefs, sexual orientation, criminal records, health information, disabilities, labor union membership, genetic data, biometric data, or any other data that may similarly affect the data subject as specified by the Personal Data Protection Committee |
2. Processed Personal Data, Purposes, and Legal Basis
- Tencent will process your Personal Data for the purposes that have been informed to you prior to or at the time of collection.
- Tencent will directly collect Personal Data from you. In case where data is collected from other sources, Tencent will adhere to the strict requirements of Personal Data Protection Law.
- You are required to provide Personal Data to comply with the law, contract or due to the necessity to provide Personal Data for contract initiation. Failure to provide such data may impact the relevant proceedings.
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Contractual Basis Legal Obligation Legitimate interests Consent basis for the collection, use or disclosure of Sensitive Data |
| Financial information regarding bank account details, including account name, account number, bank name, and branch | To consider remuneration arrangements or any other benefits provided to employees or staffs of Tencent according to the employment agreement | Contractual Basis |
| Contact information provide by employees or staffs during the process of submitting a request for medical expense reimbursement, including name, address, phone number, and the illness for which the employee is receiving treatment | To process the request for medical expense reimbursement in accordance with the healthcare benefits program. |
Contractual Basis Legal Obligation |
| Health information, disability information, details about illness and treatment, healthcare and medical expenses, medical treatment details, health insurance information, life insurance information, details about accidents or hazards, significant surgical history, pre-existing medical conditions, genetic disorders, health examination results (blood type and blood test results) |
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Contractual Basis Consent basis |
| Health information regarding illnesses and injurie experienced by employees or staffs of Tencent during the work. | To send employees or staffs for receiving a medical treatment due to illnesses and injuries during the work as required by Compensation Funds Law. |
Legal Obligation |
| Illness information on medical certificates |
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Legal Obligation |
| Religious information/food allergy information | To manage health-related matters and provide lunch benefits. |
Contractual Basis Consent Basis |
| Information about social security number/ copy of social security card | Enrollment in personal insurance/contribution payment in accordance with social security laws. | Legal Obligation |
| Information about taxpayer identification/tax identification card copy | To deduct personal income tax and remit it to the Revenue Department in accordance with Tax Law | Legal Obligation |
| Payment information to employees or staffs, including details about wages, overtime payments, bonus payments, any expenses and compensation benefits. | To pay a remuneration or other benefits to employees | Contractual Basis |
| Personal information for accessing information technology systems and essential databases for work. | To grant access to necessary information technology systems and essential databases for work, including the execution of various relevant agreements. | Contractual Basis |
| Information about the work or performance of employees, including data related to clock in and out of the workplace, wage adjustments, remuneration, benefits, promotions, work history, performance evaluations, leaves, absence, and disciplinary actions. |
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Contractual Basis |
| Emergency contact information, such as name, phone number, and contact location. | To contact in emergency situations when employees are ill or have encountered accidents and they are unable to make decisions for their medical treatments, or to receive benefits from Tencent, or in case where contacting the employees have been difficult due to consecutive work absences. | Legitimate interests |
| Family information, such as names of parents, siblings, spouse, and children |
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Legitimate interests Legal Obligation |
| Data obtained from Closed-Circuit Television (CCTV) Cameras |
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Vital Interests Legitimate interests |
Data for recording work hours and office attendance:
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Consent basis |
| Employees and staffs’ identification data, as well as employment history at Tencent | To comply with laws and establish rights of claims, legal actions, or legal proceedings, including pursing legal actions or processes. This also includes reporting or disclosing information to government agencies, state entities, independent organizations, supervisory entities, individuals or any other entities as required by law. |
Legitimate interests Legal Obligation |
3. Personal Data that we collect and use
| We collect data from you by requesting or inquiring about that information directly from you, or gather your data from other sources, such as your previous employer, government agencies or state entities, insurance companies, healthcare facilities, or other publicly accessible sources of information. | The Personal Data that may be collected, used, or processed as specified in Section 2. |
4. Retention period for the collection of Personal Data of employees, staffs and family members is as follows:
Employment Information
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Throughout the duration of the employment agreement and for a period of 10 years following the termination of the agreement, or as required by law, or until the statutory period of limitation is reached. |
| Information according to the registration of employees, such as name-family name, gender, nationality, date of birth, age, address, commencement date of employment, job position or duties | For a period of 10 years from the last day of employment for each individual. |
| Documents related to wages payment, overtime payment, working on holiday payment, and overtime payment on holiday | For a minimum of 5 years from the date of such payment, as evidence in case the Department of Labour requires an inspection report on wage payments. |
| Information for compliance with labour protection law and social security law. | Throughout the duration of the employment agreement, as prescribed by law, or permitted to be retained for a longer period or until the statutory period of limitation is reached, whichever is longer according to the law. |
| Information for compliance with tax law, such as documents for tax payments | For a period of not less than 5 years from the date of submitting tax forms or reporting date, depending on the specific case |
| Information regarding behaviors arising from the performance of the employment agreement and/or compliance with labour protection law. | Throughout the duration of the employment agreement, as prescribed by law, or permitted to be retained for a longer period or until the statutory period of limitation is reached, whichever is longer according to the law. |
| Information related to discipline and penalties arising from the enforcement of the employment agreement and/or compliance with regulations, guidelines, announcements, orders, and work rules and as mandated by labour protection law. | Throughout the duration of the employment agreement and for a period of 10 years following the termination of the agreement, regardless of the reason, or as required by law, or until the statutory period of limitation is reached. |
Personal Data of employees
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Throughout the duration of the employment agreement and for a period of 10 years following the termination of the agreement, regardless of the reason. |
| Religion Information/Food Allergy Information | It will be retained for as long as necessary according to the purpose of data collection, or until you withdraw your consent. |
| Health Information, disability information, detail of illnesses, treatment, and expenses, medical treatment information, health insurance, life insurance, accident or hazard information, significant surgical history, pre-existing medical conditions, genetic disorders, health examination results (blood type and blood test results). | It will be retained for as long as necessary according to the purpose of data collection, or until you withdraw your consent. |
| Information related to workplace accidents, injuries, or fatalities | Throughout the duration of the employment agreement and for a period of 10 years following the termination of the agreement, regardless of the reason. |
| Data obtained from closed-circuit television (CCTV) cameras and biometric facial recognition data for office entry. | It will be retained for as long as it is necessary to fulfill the purposes for which the data is being processed. |
Data for recording work hours and office entry-exit:
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It will be retained for as long as it is necessary to fulfill the purposes for which the data is being processed |
However, after the aforesaid period, we will:
- delete, destroy when the use of Personal Data is no longer necessary; or
- make your Personal Data unable to identify you for other beneficial purposes.
5. Disclosure of your Personal Data to external parties
In order to fulfill the purposes specified in this Privacy Policy Tencent may disclose your Personal Data to the following external parties:
- Affiliated companies and group companies located abroad, including executives, board members, employees, contractors, and/or personnel within those companies, to the extent permitted and necessary for the processing of your Personal Data
- Professional consultants, such as auditors, legal advisors, attorneys, or other experts, both internal and external group companies of Tencent
- Agencies, Contractors, and/or Service Providers who provide service to Tencent, acting as data processors, such as data custodians, transportation service providers, marketing agencies, companies providing training or seminar services, and other similar service providers
- Business partners (in cases where it is necessary for the performance of contractual obligations related to joint projects or business activities).
- Government agencies, state organizations, independent organizations, regulatory bodies, or other entities as required by law. This may include official who exercises legal authority such as, courts, the Royal Thai Police, Social Security Office, Anti-Money Laundering Office, and Revenue Department, etc.
- External organizations that the company has contracted with or assigned to access personal data, such as insurance companies, hospitals, and medical facilities.
- Bank or financial institutions
- Assignees of rights, duties, and benefits from the company, including those who have been delegated by the assignees to act on their behalf, such as in cases of restructuring, mergers, demergers, or business transfers etc.
- Other external individuals, such as individuals whose data may be disclosed through the company’s online social media channels, individuals involved in public relations activities, or individuals to whom the company disseminates information about its activities through mass media and external communications, etc.
6. The disclosure or transfer of Personal Data to foreign countries
In certain cases, for the benefit or necessity to achieve the purposes related to Personal Data processing as stated above, Tencent may be required to disclose your Personal Data to oversea entities, which may have different data protection standards from those in Thailand. This is because Tencent has the group companies located abroad and may conduct business or transactions with oversea companies. Therefore, we may need to disclose your Personal Data to those companies. Additionally, Tencent may store your data on computer servers or cloud service providers located abroad and may process the data using programs or applications provided by oversea service providers. However, for the disclosure or transfer of Personal Data to foreign countries in whatsoever case, Tencent shall comply with the Personal Data Protection Act B.E. 2562 (2019).
7. Your rights as the Data Subject under the Personal Data Protection Law
The Personal Data Protection Act B.E. 2562 (2019) aims to enhance the control that you have over your Personal Data. You can exercise your rights under the Personal Data Protection Act B.E. 2562 (2019), which has the following details:
- The right to withdraw your consent (unless the consent withdrawal is restricted by law or contract that benefits you as the Data Subject.)
- The right to access, obtain, and request disclosure of the source of your Personal Data that we collect, unless we have the right to refuse your request under the law or a court order, or if your request may adversely affect the rights and freedoms of other individuals.
- The right to request the rectification of your inaccurate or incomplete Personal Data in order to ensure its accuracy, currency, completeness, and to prevent any misunderstandings.
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The right to suspend the use of your Personal Data in any of the following situations:
- When we are conducting an examination based on your request to rectify your Personal Data for its accuracy, completeness and currency.
- Your Personal Data is collected, used, or disclosed without your consent or against the law.
- When your Personal Data is no longer necessary for the purposes, we have informed you during the collection process, but you wish us to continue storing the data for the exercise of your legal rights.
- When we are verifying the legal grounds for the collection, use or disclosure of your Personal Data for public interest purposes due to the fact that you have exercised your right to object to the collection, use or disclosure of your Personal Data.
- The right to object to the collection, use, or disclosure of your Personal Data, unless we have legitimate grounds to reject your request in accordance with the law.
- The right to request the deletion, destruction, or anonymization of your Personal Data, making it unable to identify you as the Data Subject.
- The right to request the transfer of your Personal Data to another Data Controller or to yourself, in certain circumstances and as permitted by law.
- The right to lodge a complaint if Tencent violates or fails to comply with the Personal Data Protection Act B.E. 2562 (2019).
8. The security of your Personal Data
We have implemented appropriate measures to ensure the security of your Personal Data, both in technical and managerial aspects to prevent data loss, unauthorized access, destruction, alteration, modification, or unauthorized disclosure of Personal Data. In addition, we have established a comprehensive data protection policy that is publicly available within our organization, which includes guidelines and practices to ensure the confidentiality, integrity, and availability of Personal Data. We regularly review and update the aforesaid internal policy, including this Privacy Policy as necessary to ensure their effectiveness.
9. Amendment of this Privacy Policy
privacy policy may be occasionally revised or amended. If there are changes or additions that impact the processing of your Personal Data, we will announce any such changes through our website and/or notify you directly via email to inform you of the amendments. However, Tencent recommends that you periodically review this privacy policy for any updates or amendments.
10. Contact Channels
If you have any questions, concerns, or inquiries regarding the protection of your Personal Data, data collection, usage, disclosure, or exercise of your rights, or if you have any complaints, you can contact us through the following channels:
Data Controller: Tencent (Thailand) Company Limited
Contact Place:8 T One Building, 10th Floor, 11th Floor, and 12th Floor (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Phra Khanong, Khlong Toei, Bangkok 10110
Telephone: 02-833-3000
Fax: 02-833-3113
Data Protection Officer
Contact Place:8 T One Building, 10th Floor, 11th Floor, and 12th Floor (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Phra Khanong, Khlong Toei, Bangkok 10110
Telephone: 02-833-3000
Email: