1. Our Privacy Statement
CocoaSAP Platform Co., Ltd. (the “Company” or “we”) has established and disclose this Privacy approach to explain how we process personal data of our customers, vendors, and other business partners including its corporate entity’s individuals such as its employees, contact persons, and directors since the protection of your personal data is of great importance to us.
2. Personal Data to be Collected
Regarding the PDPA, personal data means any information relating to an individual, which enables the identification of such individual, whether directly or indirectly, but not including the information of the deceased persons in particular.
We collect the following personal data for processing to achieve the purposes as herein with the legal basis provided for in the PDPA. In addition, we may process your personal data of a sensitive nature, including your religious beliefs and health information, in accordance with special criteria provided for in the PDPA. We collect your personal data directly from you or your personal data may be collected from the recruitment agency company.
i. General Personal Data
Name, Surname, Address, Email, Phone number, Line ID, Passport number, copy of your Passport, Date of birth, Gender, Age, Photo, copy of your ID card, Tax ID number, and images caught on CCTV cameras
ii. Sensitive Personal Data
Religious beliefs; health information
3. Purpose of Processing of Personal Data
The Company collect, use, or disclose your Personal Data for various purposes depending on relationship between you and the Company as follows:
- To consider entering into an agreement or to take steps as per an application in relation to our products or services or to enter into an agreement with you
- To provide products, benefits or services of the Company, to perform contractual obligations, to register for providing services in relation to products and services, payment, to receive or deliver the information or documents between you and the Company including to comply with our internal procedures
- To perform contractual obligations and monitor your work performance under the contract between you and the Company, including to monitor security during work performance, and to comply with our internal procedures (for example, payment, receipt or delivery of documents between you and the Company, issuance of building entry card, accident management during product shipment, etc.)
- To manage our relationship with customers, for example to communicate with you on any information about our products and services, to manage your complaint, etc.
- To inform any information or notifications to you about products or services that you have with us including other products or services of the Company, to inform benefits, sales promotion, marketing activities, any activity and project invitation of the Company and to communicate about such activity and project including to offer our products or services
- To record your information in the Company’s database
- To comply with relevant regulations such as tax laws
- To manage risks and undertake internal prevention, audit and administration to comply with laws, and to report information to government authorities as required by laws or upon receiving an order or a writ of attachment from the authority
- To control access to the buildings and premises, and to observe, prevent, deter, and (if necessary) investigate unauthorized access to buildings and premises for the purpose of monitoring security of the buildings and premises of the Company
4. Legal Basis for Processing of Personal Data
The legal basis for the processing of your personal data is as follows:
- When required by the law, a consent shall be obtained;
- When the processing activity is necessary for the performance of contractual obligations to perform contractual obligations between you and the Company;
- When the processing activity is required for the pursuit of legitimate interests of the Company;
- When the processing activity is required for the compliance with our legal obligations.
You have the right to withdraw your consent at any time by the method separately designated by us at the timing of obtaining your consent. However, your withdrawal of consent will not affect the legality of processing conducted based on your consent before its withdrawal.
We will notify you separately, if the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as the possible consequences of failure to provide such data.
5. Retention Period for Personal Data
We will retain your personal data for as long as necessary to fulfill the aforementioned purposes for obtaining and processing your personal data. Specific criteria used to determine our retention periods are the duration we have an ongoing relationship with you, the compliance with applicable laws, the compliance with legal prescription to exercise the rights to legal claims or defend against the rights to legal claims and the necessity of retaining the personal data for other legal or business reasons.
Please kindly be ensured that the retention of personal data after the expiry date of retention period will only occur only in the necessary circumstance. When the retention period has ended or the retention of such data is no longer necessary (whichever is applicable), we will destroy or erase such data from our system.
6. Disclosure of Personal Data
- Subsidiaries, affiliates and any related companies for business purposes
- Government authorities, or other authorities as stipulated by laws, including competent officials, e.g., courts, police officers, the Revenue Department, the Social Security Office, the Department of Labour Protection and Welfare, etc.
- Agencies, service providers and/or sub-contractors for their implementation and procedures, for example, accounting company, tax consultants and work permit agency company
7. Your Rights as a Data Subject
You have the following rights regarding personal data obtained and processed by us.
- Obtaining information regarding processing of data: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you.
- Access to personal data: You have the right to obtain from us confirmation as to whether personal data concerning you are being processed, and, if so, then access to the personal data and certain related information.
- Rectification or erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and the right to have us complete any incomplete personal data. Also, if certain conditions are satisfied, you will have the right to have us delete personal data concerning you without undue delay.
- Restriction on processing of personal data: If certain conditions are satisfied, you will have the right to have us restrict processing of personal data concerning you.
- Objection to processing of personal data: If certain conditions are satisfied, you will have the right to object to processing of personal data concerning you.
- Data portability of personal data: If certain conditions are satisfied, you will have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and the right to transfer those data to another controller without hindrance from us.
- To be subject to automated decision-making: If certain conditions are satisfied, you will have the right not to be subject to solely data-based, automated decision-making (including profiling) that produces any legal or similar material effect on you.
8. Data Protection Security Measures
The Company implements appropriate and strict security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of personal information.
In case where the Company assigns any third party to process your personal information pursuant to the instructions given by or on behalf of the Company, the Company shall appropriately supervise such third party to ensure your personal information protection in accordance with the PDPA.
9. Contact details
Published on 16th June 2022