Personal Data Privacy Policy In Compliance
with the Personal Data Protection Act, B.E. 2562 (2019)

Paradigm Pharma (Thailand) Company Limited (“Company”) realizes the importancy of the personal data protection and compliance on the management of Personal Data which are consistent with Personal Data Protection law and the related laws.

This Privacy Policy explains our practices regarding the collection, use or disclosure of personal data including other rights of the Data Subjects in accordance with the Personal Data Protection Laws.

The Company would like to notify you that the Company is in good compliance with the Personal Data Protection Act, B.E. 2562 (2019) and the privacy notice is hereby given as follows:

Privacy Policy for Customer
Paradigm Pharma (Thailand) Co., Ltd. recognizes the importance of the protection of your personal data. This Privacy Policy explains our practices regarding the collection, use or disclosure of personal data including other rights of the Data Subjects in accordance with the Personal Data Protection Laws.

1. Definition
“Data Subject” refers to a person who owns such personal data, but not in a case that the person has ownership or is the creator or collector of such data. The data subject shall refer to a natural person and does not include a juridical person constituted by law such as company, association, foundation or any other organizations.

“Personal Data” means any information that can identify you personally or may be able to identify you whether directly or indirectly, such as your name, email address, company name, job title and company address And the Company may collect additional personal information about you, such as your date of birth, home address, telephone number. Online user identity (eg. Social Media Accounts), marital status and family details, but not including the information of the deceased Persons in particular.

“Sensitive Personal Data” means Personal Data pertaining to racial, ethnic origins, political opinions, cult, religious or philosophical beliefs, sexual orientation, criminal records, health data, disability, trade union information, genetic data, biometric data (such as fingerprints or facial recognition data) or of any data which may affect the data subjects in the same manner, as prescribed by the Personal Data Protection Committee

“Data Protection Officer” refers to a committee by which Paradigm Pharma(Thailand) Company Limited has appointed to act on its behalf

“Data Processor” refers to the individual(s) who shall process on the collection, use or disclosure of personal data pursuant to the orders given by or on behalf of a Data Controller

The Company will collect your personal data that receive directly from you as shown in the following items:

• Membership
• Your message
• First name, Last name
• Address
• Email
• Mobile phone number
• Facebook Login
• Google Login
• LINE ID

including filling in various online forms such as registration or various contacts through the Company’s social media channels, which will be information related to your identity and contact information or any other information that will be useful in the service

2. Types of Data Collected
In the direct collection, use, and disclosure of your Personal Data, the company shall solicit your consent should it be legally required and shall use the Personal Data only as necessary and only in accordance with the Company’s specified purposes. The Company will explicitly request for consent from the Data Subject prior to the collection of Sensitive Personal Data unless such collection of Personal Data and Sensitive Personal Data falls under an exception provided under the Personal Data Protection Act B.E.2562 or other related laws.

The collection of data shall include the followings:
2.1 Personal data such as name, surname, age, date of birth, nationality, identification card, passport, etc.
2.2 Contact information such as address, telephone number, e-mail address, etc.
2.3 Account details such as username, password, transactions history, etc.
2.4 Proof of identity such as copy of identification card, copy of passport, etc.
2.5 Transaction and Financial information such as purchase history, credit card details, bank account, etc.
2.6 Technical data such as IP address, Cookie ID, Activity Log, etc.
2.7 Other such as photo, video, and other information that is considered personal data under the Personal Data Protection Laws.

3. Storage of Data
The Company shall store your personal data either as hard copy or electronic form.

4. Children and Person with Disabilities
If you are under the age of 20 or having legal restrictions, the Company may collect use or disclose your personal data. The Company require your parents or guardian to be aware and provide consent to the Company or allowed by applicable laws. If the Company become aware that the Company have collected personal data from children without verification of parental consent, the Company take steps to remove that information.For Person with Disabilities, the Company shall strictly collect information in accordance with the related laws and/or under the order with the Court, as the case, may be.

5. Use of Data
The Company use the collected data for various purposes:
5.1 To create and manage accounts
5.2 To provide products or services
5.3 To improve products, services, or user experiences
5.4 To share and manage information within organization
5.5 To conduct marketing activities and promotions
5.6 To provide after-sales services
5.7 To gather user’s feedback
5.8 To process payments of products or services
5.9 To comply with our Terms and Conditions
5.10 To comply with laws, rules, and regulatory authorities

6. Disclosure of Personal Data
The Company may disclose your personal data to the following parties in certain circumstances:

6.1 For Organization purpose, the Company may disclose your personal data within our organization to provide and develop the Company’s products or services. The Company may combine information internally across the different products or services covered by this Privacy Policy to help the Company be more relevant and useful to you and others.

6.2 Service Providers the Company may use service providers to help the Company provide the Company’s services such as payments, marketing and development of products or services. Please note that service providers have their own privacy policy.

6.3 Law Enforcement Under certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests by government authority such as courts, government authorities.

6.4 Cross-Border Data Transfer the Company may disclose or transfer your personal data to third parties, organizations or servers located in foreign countries. The Company will take steps and measures to ensure that your personal data is securely transferred, and the receiving parties have an appropriate level of personal data protection standard or as allowed by laws.

7. Data Retention
The Company will retain your personal data for as long as necessary, but in any case not more than five (5) years during the period you are a customer or under relationship with the Company, or for as long as necessary in connection with the purposes set out in this Privacy Policy, unless law requires or permits a longer retention period. The Company will erase, destroy or anonymize your personal data when it is no longer necessary or when the period lapses.

8. Data Subject Rights
Subject to the Personal Data Protection Laws thereof, you may exercise any of these rights in the following:

8.1 Right to withdrawal of consent: If you have given consent to the Company to collect, use or disclose your personal data whether before or after the effective date of the Personal Data Protection Laws, you have the right to withdraw such consent at any time throughout the period your personal data available to the Company, unless it is restricted by laws or you are still under beneficial contract.

8.2 Right to access to the Personal Data: You have the right to access your personal data that is under the Company’s responsibility; to request the Company to make a copy of such data for you; and to request the Company to reveal as to how the Company obtain your personal data.

8.3 Data portability: You have the right to obtain your personal data if we organize such personal data in automatic machine-readable or usable format and can be processed or disclosed by automatic means; to request us to send or transfer the personal data in such format directly to other data controllers if doable by automatic means; and to request to obtain the personal data in such format sent or transferred by us directly to other data controller unless not technically feasible.

8.4 Objection: You have the right to object to collection, use or disclosure of your personal data at any time if such doing is conducted for legitimate interests of the Company, corporation or individual which is within your reasonable expectation; or for carrying out public tasks.

8.5 Data erasure or destruction: You have the right to request the Company to erase, destroy or anonymize your personal data if you believe that the collection, use or disclosure of your personal data is against relevant laws; or retention of the data by us is no longer necessary in connection with related purposes under this Privacy Policy; or when you request to withdraw your consent or to object to the processing as earlier described.

8.6 Suspension: You have the right to request the Company to suspend processing your personal data during the period where we examine your rectification or objection request; or when it is no longer necessary and the Company must erase or destroy your personal data pursuant to relevant laws but you instead request the Company to suspend the processing.

8.7 Rectification: You have the right to rectify your personal data to be updated, complete and not misleading.

8.8 Complaint lodging: You have the right to complain to competent authorities pursuant to relevant laws if you believe that the collection, use or disclosure of your personal data is violating or not in compliance with relevant laws.

You can exercise these rights as the Data Subject by contacting the Company as mentioned below. The Company will notify the result of your request within 30 days upon receipt of such request. If the Company deny the request, the Company will inform you the reason.

9. Advertising and Marketing
The Company may send certain information or newsletter for the purpose of utilizing your preference via your email. If you no longer want to receive the communications from the Company, you can click the “unsubscribe”.

10. Cookies
To enrich and perfect your experience, the Company use cookies or similar technologies to display personalized content, appropriate advertising and store your preferences on your computer. The Company use cookies to identify and track visitors, their usage of website and their website access preferences. If you do not wish to have cookies placed on your computer you should set their browsers to refuse cookies before using the Company website.

11.Data Security
The Company endeavor to protect your personal data by establishing security measures in accordance with the principles of confidentiality, integrity, and availability to prevent loss, unauthorized or unlawful access, destruction, use, alteration, or disclosure including administrative safeguard, technical safeguard, physical safeguard and access controls.

12. Changes to this Privacy Policy
The Company may, from time to time, review this Policy for compliance with the changing guidelines and relevant laws. In case of changes thereto, the Company will provide a public notification through appropriate channels.

13. Links to Other Sites
The purpose of this Privacy Policy is to offer products or services and use of the Company website. Any websites from other domains found on the Company site is subject to their privacy policy which is not related to the Company.

14. Contact Information
Enquires or questions on this Privacy Policy or your rights can be addressed to the following below:

Paradigm Pharma (Thailand) Co., Ltd.
Mrs. Pitiporn Dechapanichkul (acting as the Data Protection Officer)
Human Resource Manager
email: pitiporn@paradigmpharma.com
02-685 3000 ต่อ 19

Given on this day, 1st June 2022