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Privacy Policy
For trainings, seminars, corporate social responsibility activity, or any events joiners

Last modified on 29 September 2023

Tencent (Thailand) Company Limited (hereinafter referred to as “Tencent” or “We”) places great importance on the protection of your Personal Data. 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 acknowledge you as the external who join trainings, seminars, corporate social responsibility activity (CSR) or any events held by Tencent to acknowledge the detail of how we process your Personal Data includes to inform you of your right as the Data Subject according to 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:

  1. Tencent Online (Thailand) Ltd.
  2. Webspace Ltd.
  3. MWEB Portal (Thailand) Ltd.
  4. Levelup Online Co., Ltd.
  5. Topspace (Thailand) Co., Ltd.
  6. WeChat (Thailand) Co., Ltd.

1. Definition

Vocabulary 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 joiners of trainings, seminars, corporate social responsibility activity (CSR), or any events held by Tencent
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. The purpose of collection, user or disclosure of your Personal Data

Personal Data that may be collected / processed The purpose of collection, uses, or disclosure of your Personal Data Legal basis
Name – family name, age, copy of identification card or passport of the activity joiners
  1. To register you in trainings, seminars, CSR activity, or any activity of Tencent
  2. To verify the number of trainings, seminars, CSR activity, and any activity of Tencent joiners and their history of joining to prepare the facility
  3. To arrange insurance related to the activity
  4. To deliver rewards or any competition regards trainings, seminars, CSR activity, or any activity of Tencent (if any)

Contractual Basis

Legitimate interests

Contact channel includes telephone number, Email, Line, or current address of the joiners
  1. To contact joiners of trainings, seminars, CSR activity, or any activity of Tencent for holding such event
  2. To inform the detail of trainings, seminars, CSR activity, or any activity of Tencent such as joiners’ name, date, time, and place
  3. To deliver news or marketing material of Tencent (if any)

Contractual Basis

Legitimate interests

Consent Basis

Information of activity joiners regards the interest of product/service related to trainings, seminars, CSR, or any activity of Tencent
  1. To be used for contact and approach the product /service of Tencent which the joiners’ interest by sale person/employee of Tencent
  2. To analyze and marketing research for developing the product and service includes the marketing purpose of Tencent

Legitimate interests

Consent Basis

Information related to lifestyle and society such as a hobby or your interest (if any) To prepare trainings, seminars, CSR activity, or any activity of Tencent or hold suitable counter such as analysis and hold the activity and place

Legitimate interests

Educational background, work background, job position
  1. To prepare suitable trainings, seminars, course of seminars or activity for joiners
  2. To be used as a stakeholder's database of Tencent and/or used to manage relationships or contact related to Tencent

Legitimate interests

Information related to comment or expectation, the satisfaction of joining trainings, seminars, CSR, or any activity of Tencent (if any) To be used to evaluate, analyze, and improve trainings, trainings, seminars, CSR activity, or any activity of Tencent

Legitimate interests

Information related to joining any activity such as registration, taking pictures, VDO or voice recording, or any motion record
  1. For use in promoting trainings, seminars, CSR activity, or other activities organized, conducted, or sponsored by Tencent through online or offline media channels, Tencent's website, advertisements, or printed materials, among others.
  2. To use personal photographs or video clips of individuals in promotional materials for trainings, seminars, CSR activity, or other activities, or for setting up booths organized, conducted, or sponsored by Tencent.
  3. To use event ambiance photographs as evidence and supporting materials for activity organization, for inspection by regulatory agencies, as well as for promoting events through online or offline media channels, Tencent’s website, or external entities.

Legitimate interests

Consent Basis (in case capture or VDO record of the individual)

Health information/ food allergy information (if necessary)
  1. For the management of your health, nutrition, and safety during your participation in the activities.
  2. For compliance with laws related to public health benefits, such as the prevention of infectious diseases or epidemic diseases as declared by the Ministry of Public Health.

Legal Obligation

Consent Basis (in case of food allergy)

Information received from CCTV
  1. To prevent dangers to life, body, or health, as well as for the maintenance of internal security within Tencent’s premises, use closed-circuit television (CCTV) cameras.
  2. For the lawful benefits of Tencent, customers, and other individuals.

Vital Interests

Legitimate interests

Identification information and contact information includes telephone number, Email, address of activity joiners For compliance with various laws and for the establishment of rights, claims, or legal actions, including initiating legal proceedings and reporting or disclosing information to government units, state organizations, regulatory agencies, individuals, or any other entities as required by law.

Legitimate interests

Legal Obligation

Personal Data collected by Tencent is necessary for the purpose of compliance with contractual obligations or legal requirements that are enforceable. If you do not provide the necessary Personal Data as mentioned above, Tencent may not be able to allow your participation in trainings sessions, seminars, or various activities organized by Tencent, or may not be able to carry out contractual management or provide you with the requested services.

3. Personal Data that we collect and use

The sources / methods of collecting Personal Data Lists of Personal Data that may be collected
We collect data from you by requesting or inquiring about that information directly from you or collect your information from other sources such as external organization who held the activity (if any) The Personal Data that may be collected, used, or processed as specified in Section 2

Reservation of Rights : Tencent hereby wishes to inform you that in the event we require documentation to verify your identity, such as an identification card, passport, or any other documents containing sensitive data, including religious information, Tencent has no intention of retaining such information. Therefore, we kindly request that you, as the data subject, take the necessary measures to erase or securely store such Personal Data. Should you fail to comply with this notification, Tencent reserves the right to consider that Tencent has not retained the aforementioned data.

4. Retention period for the collection of Personal Data

We only retain your Personal Data to the extent necessary for the purposes of collecting, using, or disclosing personal information as stated in clause 2 above. The retention period includes the period during which you maintain a relationship with us as a participant in the trainings, seminars, CSR activity, or any other relevant events. Additionally, Tencent may find it necessary to continue storing your Personal Data for compliance with legal obligations or statutory limitations, establishing claims according to the law, complying with or asserting legal rights, or for other reasons in accordance with Tencent's internal policies and regulations.

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:

  1. 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
  2. The consultants of Tencent, such as auditors, legal advisors, attorneys, or other experts, both internal and external group companies of Tencent (Thailand) Company Limited.
  3. Government authority, government organization, independent organization, regulatory organization, or any other organization as required by law include an officer who has authority to do so such as the court, prosecutor, police officer
  4. Insurance agent and/or insurance company
  5. Representatives, contractors, and/or service providers engaged by Tencent in the capacity of Personal Data processors, such as companies contracted for marketing activities, media production, public relations, event organizing, trainings institutions, and speakers or trainers.
  6. General individual (specifically to promote images or information regarding the organization of trainings, seminars, CSR activity, other events, or announcing the list of competition winners and prize recipients) through both online and offline media channels, including those of Tencent and external individuals such as "what's new", internal organization PR, Facebook, Line, Twitter, YouTube, Tiktok, Discord, and Website including but not limited to posters, banners, advertisements, newspapers, and TV.
  7. Hospital or medical facility

6. Transfer to disclose information to a foreign country

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 right as a data subject according to 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:

  1. The right to withdraw your consent (unless the consent withdrawal is restricted by law or contract that benefits you as the Data Subject.)
  2. 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.
  3. 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.
  4. The right to suspend the use of your Personal Data in any of the following situations:
    1. When we are conducting an examination based on your request to rectify your Personal Data for its accuracy, completeness and currency.
    2. Your Personal Data is collected, used, or disclosed without your consent or against the law.
    3. 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.
    4. 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.
  5. 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.
  6. The right to request the deletion, destruction, or anonymization of your Personal Data, making it unable to identify you as the Data Subject.
  7. 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.
  8. The right to lodge a complaint if Tencent violates or fails to comply with the Personal Data Protection Act B.E. 2562 (2019).

8. 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

This 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

Address:
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
Facsimile: 02-833-3113

Data Protection Officer

Address:
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: