1. Clients

• Lessees of lands, buildings, or structures
• Prospective buyers of land, buildings, or structures
• Recipients of services provided by the Company
• People who contact us to inquire about our products and services
• People who receive our product and/or service information through various channels
• People who receive offers or solicitations from brokers or agents to buy lands, buildings, or structures

2. Business partners

• Investors
• Business operators who have vested interests in the
  Company
• People who negotiate investments or joint ventures
  with the Company

3. Suppliers

• Contractors and subcontractors
• Agents/brokers
• Salespersons

4. Employees

• Permanent employees
• Contract employees
• Outsourced employees
• Interns
• Former employees

5. Job applicants

People who have submitted a job application and are in the process of job interview, including related persons such as fathers and mothers, whose information is provided by the applicant in the job application

6. Shareholders, trust unitholders, directors, and executives

• Shareholders, including holders of shares and securities in the Company
• Trust unitholders
• Directors, which include board members, independent
  directors, audit directors, executive directors, and other directors no matter what they are called, but not including personal information of the above individuals related to their performance as employees or officers of the Company
• Related parties, which include parents, spouses, siblings, children (including adopted children), and spouses of children of directors and proxies/attorneys in fact of shareholders, trust unitholders or directors
• Personal assistant, secretary, and coordinator of shareholders, trust unitholders and directors

7. Local communities

• Community leaders
• Members of the general public who participate in the
  projects of our Community Relations Department

8. Other people whose information may be collected, used, or disclosed by the Company

For example:

• Mass media
• Visitors
• Parcel delivery staff

We will collect and process your personal information if you are an individual associated with a juristic person or government agency that has a relationship with the Company in the following cases.

1. Natural persons associated with juristic persons that have a relationship with the Company. Juristic persons shall mean including but not limited to companies, universities, associates and chamber of commerce.

Natural persons associated with juristic persons that have a relationship or conduct transactions with the Company, such as:
• Shareholders (natural persons)
• Directors
• Signatories
• Authorized officers or persons
• Consultants, such as legal advisors and auditors. In the
case where a consultant is a juristic person, this shall include natural persons related to that consultant

2. Public officials

Officials affiliated with government agencies, such as:
• Industrial Estate Authority of Thailand
• Revenue Department
• Thailand Board of Investment
• Securities and Exchange Commission
• The Stock Exchange of Thailand
• Bank of Thailand
• Department of Business Development
• Local government agencies, such as provincial
administrative organizations and subdistrict administrative organizations

Information relating to an individual
Title, first name, last name, nickname, gender, age, and date of birth; national identification number; taxpayer identification number; social security number; provident fund member number; family status; military status; personal background; education and training information; work history; information that appears on a document issued by a government agency, professions council, or educational institution (such as national identity card, driver’s license, professional license, diploma, academic transcript, and other educational certificates); skills and expertise; hobbies; activities participated; job position applied for; expected salary; job interview evaluation results and feedback; physical attributes such as facial features, weight, height, voice, image, video, and CCTV data; and signature

Contact information
Address, phone number, (mobile and landline), e-mail address, and Line ID

Account information
Bank account number, account name, bank/branch where the account is opened, and other information that appears on the front page of the bank account book

Employment information
Years of service; position; department; division; employee ID; salary; bonus; welfare and benefits; contributions deducted to applicable funds; performance evaluation results and feedback; information about entering and leaving the workplace; reimbursement record; approvals of works under yourresponsibility; accessing, using, printing, and photocopying information stored in the system; system usage; sending and receiving emails; absence from work or leave; exercise of labor protection or welfare rights; complaints, warnings, and disciplinary actions; and termination of employment (e.g., resignation/dismissal, reasons for dismissal, and termination date)

Qualification information of shareholders, trust unitholders or and directors
Shareholding information (including partnership); record of serving as a director, employee, consultant, auditor, or controlling person in the Company or other companies (including other partnerships); information about relationships by blood or by registration with a director, executive, major shareholder, or controlling person of the Company or its subsidiary or associated company; information about business relationships with the Company or its parent, subsidiary, or associated company, major shareholder, or controlling person of the Company; information about business undertakings; information about unlawful conducts including accusation, prosecution, judgment, and punishment (including disciplinary action and request rejection by a government agency); information about financial status and competencies; record of training and other information required by government agencies

Information about performance of directors and executives
Position; term of office; remuneration including meeting allowance and bonus; benefits and use of these benefits; information about entering and leaving the workplace; reimbursement record; attendance of meetings, voting, expressing opinions, and passing resolutions at meetings; and termination of office

Information about trust units, shares and shareholder and/or trust unitholders meetings
Number of shares/trust units held; share/trust unit numbers; share/ trust unit value; record of share/trust unit transfers, share/trust unit purchases, payments, and dividends received; return on investment; attendance of meetings, voting, expressing opinions, and passing resolutions at meetings; and exercise of rights relating to shares/ trust units

Behavioral information
Behavior about purchasing products and services of the Company, inquiries, suggestions or comments, user behavior on our website, and electricity and water consumption (electricity and water bills)

Asset information
Information that appears on title deeds purchased (e.g., deed number, plot number, and plot plan), details of water and electricity meters transferred, and leased properties and floor plans

Transaction information
Information that appears on advance orders (e.g., advance order number, property order, and payment); purchase price; service fee; rental fee; security deposit; rental payment information; fee and tax payment information; date of advance order and transfer date; rental period; complaints, suggestions, and feedback; other status of property transactions; property repairs within the warranty period; common area services; and commercial space leasing including associated commercial activities

Where necessary and permitted by law, we may collect sensitive personal information, which may create significant risks to, interference with, or discrimination against the exercise of your rights and freedoms. To accomplish the purposes described in this Privacy Notice, we may collect the following sensitive personal information:

Information relating to an individual
- Information that appears on documents issued by government agencies, such as nationality, religion, and blood type (if any)
- Race
- Biometric data, such as fingerprints

Health information
Information about health and physical disabilities, information on a medical certificate, accidents and illness, and screening for respiratory diseases

In addition to the above personal information, we may collect other categories of personal data, where it is necessary or permitted by law, in strict compliance with personal data protection rules and standards.

We collect data directly from you

• When you apply for a job by submitting an application and resume directly to the Company or through the website or other recruitment agencies. When you are initially selected, we may request your consent to collect and process personal data from the results of your medical examination as necessary.
• Once you pass the selection, we will collect additional personal data from you for the purpose of preparing an employment contract and personnel file and providing welfare benefits for you in accordance with our terms and conditions.
• During the course of employment, when you perform the assigned duties or when you exercise your labor protection or welfare rights.
• Upon the termination of your employment contract.
• When you complete our survey.
• When you enter our office area, you may need to screen for respiratory illness by measuring body temperature and filling out a questionnaire, or following appropriate measures.
• When you pass your contact information to us, e.g., by giving us your business card.
• When you provide information for preparing or performing a contract or agreement.
• When you give consent to be nominated for the Company's director and provide us with information to verify your eligibility.
• When you attend a board meeting and perform duties as a director/executive.
• Through any other means as will be notified.

We collect data through electronic devices

• CCTV cameras installed in our office area and other areas under our management.
• Photos and videos of you that we take at events.
• We collect your fingerprint data through a fingerprint scanner.
• We collect your personal data when you use our information system and internet.
• Through any other means as will be notified.

We collect data from third parties

• We may receive your information from third parties, such as our clients, suppliers, business partners. and regulators.
• Through any other means as will be notified.

We collect data from public sources

• We collect your personal data through media such as news on the internet.
• We collect your publicly available data through websites of government agencies, such as the Department of Business Development and Department of Industrial Works.

Purpose of Processing / Legal Base for Processing

4.1.1 To create a database and facilitate communication.
- Contractual Basis
- Legitimate Interest

4.1.2 To offer our products and services, and for marketing purposes.
- Contractual Basis
- Legitimate Interest

4.1.3 To prepare, revise, or terminate contracts, such as property and land lease agreements, land purchase agreements, transfer of ownership agreements, and service contracts, including authorization to execute these acts.
- Contractual Basis
- Legitimate Interest

4.1.4 To transfer land ownerships and register leasehold rights, including authorization to execute these acts.
- Legal Obligation (processing nationality data of property purchasers)
- Contractual Basis
- Legitimate Interest

4.1.5 To collect, receive, and make payments, such as land purchases, rents, security deposits, fees, and utility service fees, including to take any action to settle disputes.
- Contractual Basis
- Legitimate Interest

4.1.6 To expand opportunities for investment.
- Legitimate Interest

4.1.7 To organize banquets, meetings, and presentations.
- Legitimate Interest

4.1.8 To conduct survey and prepare report such as satisfaction survey
- Legitimate Interest

Purpose of Processing / Legal Base for Processing

4.2.1 To create a database and facilitate communication.
- Contractual Basis
- Legitimate Interest

4.2.2 To select suppliers.
- Legitimate Interest

4.2.3 To prepare, revise, or terminate contracts,such as construction contracts, consulting contracts, service contracts, loan agreements, and financial agreements.
- Contractual Basis
- Legitimate Interest

4.2.4 To collect, receive, and make payments, such as payments and refunds of construction security deposits, disbursements of goods and services, commission fees, and issuing invoices, including to take any action to settle disputes.
- Contractual Basis
- Legitimate Interest

4.2.5 To supervise supplier’s operation such as to audit performance of the supplier and to review requests to access sites to perform works.
- Contractual Basis
- Legitimate Interest

4.2.6 To write reports, such as satisfaction survey report, supplier audit report, ISO audit reports, environment impact assessment reports (i.e.IEE, EIA, and EHIA reports), and other reports as required by law and/or to deliver such reports to the relevant organization.
- Legal Obligation
- Contractual Basis
- Legitimate Interest

4.2.7 To be used for external audits conducted by a third party and for disclosure to such third party, such as financial statement and procurement audits and other audits as required by law.
- Legal Obligation
- Contractual Basis
- Legitimate Interest

Purpose of Processing / Legal Base for Processing

4.3.1 To recruit and select new employees.
- Legitimate Interest

4.3.2 To prepare, revise, terminate, or renew contracts, such as employment contracts.
- Contractual Basis
- Legitimate Interest

4.3.3 To create personnel files used for internal use or disclosure to the relevant organization as required by law.
- Legal Obligation
- Legitimate Interest

4.3.4 To manage human resources, such as job assignment, transfer, warning and other disciplinary action, annual performance evaluation, retirement, visa and work permit, and conducting an employee development survey.
- Legal Obligation
- Legitimate Interest

4.3.5 To organize training programs to improve employee skills.
- Legitimate Interest

4.3.6 To pay compensation and provide welfare benefits to employees, withhold taxes, and pay contributions to applicable funds, such as Social Security Fund, Compensation Fund, and Provident Fund.
- Legal Obligation
- Legitimate Interest

4.3.7 To provide health checkup, life and/or health insurance, and other welfare benefits to employees.
- Legal Obligation (processing sensitive health data of employees from the annual health checkup in compliance with the law)
- Legitimate Interest

4.3.8 To issue a certificate of employment and take other actions as required by the labor protection law.
- Legal Obligation
- Legitimate Interest

4.3.9 To terminate employees and notify relevant agencies.
- Legal Obligation
- Legitimate Interest

Purpose of Processing / Legal Base for Processing

4.4.1 To create a database and facilitate communication.
- Legitimate Interest

4.4.2 To update shareholder and/or trust unitholder information and maintain the shareholder and/or trust unitholder register book.
- Legal Obligation
- Legitimate Interest

4.4.3 To convene meetings, prepare and propose meeting agenda to be approved, and prepare the minutes of shareholder and/or trust unitholder meetings.
- Legal Obligation
- Legitimate Interest

4.4.4 To prepare reports related to shareholders, and/or trust unitholders directors, and executives and disclose information to government agencies and the public including satisfaction survey report.
- Legal Obligation
- Legitimate Interest

4.4.5 To pay dividends to shareholders and/or trust unitholders.
- Legal Obligation
- Legitimate Interest

4.4.6 To prepare, revise, or terminate contracts and perform any juristic acts on behalf of the Company, including authorization to execute these acts.
- Contractual Basis
- Legitimate Interest

4.4.7 To make payments, such as payments for goods and services and commission fees, including to collect and receive payments.
- Contractual Basis
- Legitimate Interest

4.4.8 To prepare and submit permit applications, requests, or other documents to relevant government agencies, including authorization to execute these acts.
- Legal Obligation
- Legitimate Interest

4.4.9 To take legal actions, such as filing a complaint, giving a statement, pleading, counterclaiming, withdrawing a case, compromising, and execution, including authorization to perform these acts.
- Legal Obligation
- Legitimate Interest

Purpose of Processing / Legal Base for Processing

4.5.1 To create a database and facilitate communication.
- Legitimate Interest

4.5.2 To provide information and organize community relations activities.
- Legitimate Interest

4.5.3 To make disbursement of funds for donations, etc.
- Legitimate Interest

4.5.4 To prepare reports, such as sustainability report, satisfaction survey report or produce public relations materials.
- Legitimate Interest

4.5.5 To review requests to access sites to perform works.
- Legitimate Interest

Purpose of Processing / Legal Base for Processing

4.6.1 To create a database and facilitate communication.
- Legitimate Interest

4.6.2 To offer our products and services and for marketing purposes.
- Contractual Basis
- Legitimate Interest

4.6.3 To expand opportunities for investment.
- Legitimate Interest

4.6.4 To select suppliers.
- Legitimate Interest

4.6.5 To organize banquets, meetings, and presentations.
- Legitimate Interest -

4.6.6 To prepare, revise, or terminate contracts and perform any juristic acts on behalf of the Company, including authorization to execute these acts.
- Contractual Basis
- Legitimate Interest

4.6.7 To prepare and submit permit applications, requests, or other documents to relevant government agencies, including storing permits and official documents.
- Legal Obligation
- Legitimate Interest

4.6.8 To transfer land ownerships and register leasehold rights, including authorization to execute these acts.
- Legal Obligation (processing nationality data of property buyers)
- Contractual Basis
- Legitimate Interest

4.6.9 To write reports, such as satisfaction survey report, supplier audit report, ISO audit reports, environment impact assessment reports (i.e.IEE, EIA, and EHIA reports), and other reports as required by law and/or to deliver such reports to the relevant organization.
- Legal Obligation
- Contractual Basis
- Legitimate Interest

4.6.10 To supervise supplier’s operation such as to audit performance of the supplier and to review requests to access sites to perform works.
- Legal Obligation
- Contractual Basis
- Legitimate Interest

4.6.11 To collect, receive, and make payments.
- Contractual Basis
- Legitimate Interest

4.6.12 To take legal actions, such as filing a complaint, giving a statement, pleading, counterclaiming, withdrawing a case, compromising, and execution, including authorization to perform these acts.
- Legal Obligation
- Legitimate Interest

4.6.13 To be used for external audits conducted by a third party including for disclosure to such third party such as financial statement and procurement audits and other audits as required by law.
- Legal Obligation
- Contractual Basis
- Legitimate Interest

4.6.14 To prepare reports, such as satisfaction survey report or supplier audit report.
- Legitimate Interest

Parties We Disclose or Grant Access to Data to / Decription and Example

Affiliated companies
Our affiliated companies, including personnel of these companies as detailed in the attachment

Our service providers
For example, service providers of infrastructure development and maintenance, software, website, information technology. data storage and cloud, data monitoring and analysis, security, paper-based document storage and shredding, legal consulting, financial consulting, and auditing, provident fund management, life and health insurance; hospitals that provide health checkup services; commercial banks that provide financial services, recruitment service providers, job search websites, employee performance evaluation, and employee benefit actuarial valuation

Our clients and partners
Our clients and partners, which include their personnel
who have the need to access or process your personal data

Authorities and government agencies
For example, the Revenue Department, Social Security Office, Department of Empowerment of Persons with Disabilities, Department of Skill Development, police officers, courts, inquiry officials, regulators such as the Securities and Exchange Commission, Industrial Estate Authority of Thailand, and Thailand Board of Investment, and other public officials or government agencies

Individuals involved in business mergers, transfers, or restructuring
Investors, auditors, and consultants involved in the review and decision-making process relating to our business management

Other people we may disclose data to
Victims or affected people, such as employees or other third parties (including their representatives) who are suffered, violated, or harmed as a result of a criminal act, against which a complaint has been made according to the procedure specified by the Company

Public
We may disclose personal data in relation to shareholders, directors, executives, employees of the Company appeared in our reports to the public.

Trustee
Trustee administering the trust who has a trust manager appointment agreement with the Company