Crown Privacy Policy  |  Crown Equipment (Thailand) Co. Ltd

 

1. Introduction

In the course of Crown’s business in Thailand, Crown collects personal information and the Crown Privacy Policy (“Policy”) has been developed to ensure that such information is handled appropriately.

Crown is committed to complying with the Personal Data Protection Act B.E. 2562 (2019) and any regulations, rules, guidelines, notifications and orders issued by virtue thereof, as may be amended, supplemented or replaced from time to time (“PDPA”) in relation to all personal information it collects. This commitment is demonstrated in this Policy. Personal information held by Crown will be treated in accordance with the requirements under the PDPA.

This Policy sets out the broad controls which Crown has adopted to govern the way it collects and uses personal information, the circumstances in which it might disclose personal information to third parties, how persons can access their personal information held by Crown and what they can do if they are unhappy with Crown’s treatment of their personal information.

 
2. Who is Crown?

In this Policy, “Crown” refers to Crown Equipment (Thailand) Co. Ltd

 
3. Who does the Crown Privacy Policy apply to?

This Policy applies to any individuals in respect of whom Crown currently holds, or may in the future collect, personal information.

 
4. What information does the Crown Privacy Policy apply to?

This Policy applies to personal information. “Personal information” is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.

 
5. What information is not personal information?

Information where Crown has irreversibly removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.

Crown may use this information for its own purposes and commercial gain. For example, the fact that “x” users aged 30-35 have accessed a Crown website is not personal information.

 
6. How and when does Crown collect personal information?

Crown collects personal information in a variety of ways in the course of conducting its business, including:

  • in agreements it enters into with customers, suppliers, contractors and other personnel;
  • when providing equipment and services and related information to customers, and administering customer accounts;
  • when engaging suppliers, contractors and other personnel;
  • when responding to questions regarding Crown’s products and business;
  • by interacting with people via Crown’s websites, email and telephone;
  • when conducting trade promotions and competitions; and
  • by security video surveillance at Crown sites.

The kinds of personal information collected and held by Crown include (depending on the circumstances) names, addresses and other contact details, details about a person’s work experience and other qualifications, date of birth, driver’s license details, bank account details, photographs and video footage.

Where reasonable and practicable, Crown will collect personal information directly from the person. Where it may not be clear that this is being done, Crown will seek to identify that this is being done.

However, in some circumstances, it is necessary for Crown to collect personal information through third party service providers or agents (e.g. Crown customer information received from Crown branches) or from a source of publicly available information (e.g. a telephone book).

At or soon after the time when Crown collects your personal information from third parties, Crown will take reasonable steps to ensure that the person is aware that Crown has collected the information, the purpose(s) of the collection, the main consequences (if any) if the information is not collected, the types of organisation (if any) to which the information may be disclosed to (including those located overseas), any law that required the particular information to be collected, and the fact that this Policy contains details on the rights you are entitled to in relation to your personal information.

Personal information collected by Crown may be held in a variety of formats, including hard copy format and on Crown’s computer systems.

If Crown receives personal information that Crown has not requested (unsolicited information) and Crown determines that Crown does not have a legal basis to collect that information under the PDPA if Crown had requested it, then Crown will destroy or de-identify the information if it is lawful and reasonable to do so.

 
7. What kind of personal information does Crown collect? and How does Crown use personal information?

The use to which Crown can put personal information depends on the reason for which it was collected. Crown may use personal information for its primary purpose of collection (e.g. to provide our products and services, the delivery of equipment to the person, to process an application for credit) or for any related secondary purpose that Crown could reasonably be expected to use the personal information for.

In certain circumstances, Crown may use personal information for promotional or direct marketing purposes. However, a person may at any time request Crown not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below. There is no fee for making such a request.

In certain circumstances, your personal information is required for the purposes of proceeding with your request to enter into a contract with Crown (e.g. register for an account), or to perform Crown’s obligation under the contract with you (e.g. proceed with your purchase order, process your payment, delivery of goods or services to you) in which case if you do not provide the required personal information, Crown may not be able to proceed with your request, or may not be able to perform Crown’s obligations under the contract with you, either in whole or in part.

In addition, there may be certain circumstances where your personal information is required for the purposes of compliance with the law, and if you do not provide Crown with the required personal information, it may result in Crown and/or you being in violation or non-compliance with such law.

 

8. Disclosure of personal information

Crown respects the privacy of personal information and Crown will take reasonable steps to keep it strictly confidential.

Crown will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected (e.g. disclosure to a customer for the purpose of delivering equipment ordered from Crown). Where such a disclosure is necessary, Crown will require that the third party undertake to treat the personal information in accordance with the applicable legislation.

Otherwise, Crown will only disclose personal information to third parties without the consent of the person to whom it related if the disclosure is:

(a) necessary to protect or enforce Crown’s legal rights or interests or to defend any claims;
(b) necessary to prevent or lessen a serious threat to a person’s health or safety;
(c) required or authorised by law; or
(d)permitted by another exception in local legislation.

Under no circumstances will Crown sell personal information without the consent of the person to whom it relates. It is not likely that Crown will disclose a customer’s personal information to overseas recipients except where required in the direct provision of the nominated goods/services.

 

9. Information Security

Crown will take all reasonable steps to ensure that all personal information held by Crown is secure from any unauthorised access or disclosure. However, Crown does not guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosure will not occur.

Crown will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes for which Crown is authorised to use it.

 

10. Your rights

Subject to the limitations and conditions of the PDPA, you are entitled to the following rights to your personal information:

Access and deletion of your personal information

A person may request to access and obtain the personal information about them held by Crown, to request the disclosure of the acquisition of their personal information without their consent, as well as to request that their personal information be deleted, destroyed or de-identified. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below.

Crown will grant a person access to their personal information as soon as possible, subject to the circumstances of the request.

To the extent permitted by law, a request to access personal information may be rejected if it is permitted by law or pursuant to a court order, and such access and obtaining a copy of the personal information would adversely affect the rights and freedoms of others.

To the extent permitted by applicable law, Crown may charge a fee for reasonable costs incurred in giving access to an individual’s personal information. The fee (if any) will be disclosed prior to it being levied.

Correcting Personal Information

Crown will take reasonable steps to ensure the accuracy and completeness of the personal information that Crown holds. However, if a person believes that any personal information that Crown holds about them is inaccurate or out of date, then they should contact Crown via the contact details provided under the “Contact Crown” heading below.

Data portability, objection and suspension/restriction

You have the right to obtain your personal information in a format which is commonly readable and usable by automatic tools or devices and for which personal data can be used or disclosed through automatic means, and to request to have your personal information in said format transmitted to another data controller. You are entitled to object to the processing of your personal information under certain circumstances such as when your personal information is processed for direct marketing purposes or where your personal information is processed based on Crown’s legitimate interest and Crown does not have any other prevailing reasons to continue with said processing of your personal information. In certain cases, you are also entitled to request the suspension/restriction of the processing of your personal information such as when you request to have your personal information corrected or your request to object to the processing of your personal information based on our legitimate interest is still pending for examination and verification, etc.

Withdrawal of consent

Where Crown has obtained your consent for the processing of your personal information, you will be entitled to withdraw your consent at any time. However, the withdrawal of your consent would not affect the lawfulness of the processing of your personal information performed by Crown prior to such withdrawal.

 

11. Complaints

If a person wishes to complain about a breach by Crown of the Policy or the PDPA, a complaint may be lodged with Crown via the contact details provided under the “Contact Crown” heading below.

Crown deals with complaints via Crown’s internal data privacy complaint process, under which a Crown contact officer will be allocated to assess your complaint and respond to you within a reasonable timeframe. Crown takes all complaints seriously and any further action after Crown’s initial response to you will vary depending on the nature of your complaint.

You are also entitled to lodge a complaint to Thailand’s Office of Personal Data Protection Committee for Crown’s non-compliance with or violation of the PDPA.

 

12. Additional information regarding Credit Information

This Policy also applies in relation to Crown’s collection and use of credit information of individuals, in connection with commercial credit provided through Crown.

The types of credit information that Crown collects and uses for the purpose of assessing an application for commercial credit typically include:

  • names, addresses and other contact details of account holders and guarantors (both prospective and current);
  • bank account details;
  • driver’s license details;
  • financial information; and/or
  • information on the assets held by an individual.

Such information is collected from the relevant individual and from credit reporting bodies, as well as from publicly available information. Crown uses the information collected to create an internal credit assessment report.

Crown discloses credit information to credit reporting bodies:

  • to obtain a credit report from the credit reporting body; and
  • for the purposes of lodging a default listing against the individual.

When lodging a default listing Crown may do this itself or by Crown’s agents.

 

13. Google Analytics

Crown’s website also uses Google Analytics which is a web analytics tool offered by Google Inc. that generates detailed statistics about a website’s traffic and traffic sources. Crown uses Google Analytics for statistical reasons, e.g. to measure how many users have clicked on certain product information. Google Analytics uses Cookies to obtain information about your use of Crown’s website including your IP-address. As your IP-address is an individual element that would allow you to be identified, Crown has implemented a specific code to ensure that your IP-address will only be collected in a shortened and anonymised form. Thus, Google will not be able to identify you from the IP-address that is collected from you when using this website. The information collected by this Cookie will be transferred to Google Inc. in the United States of America. 

 

You may opt out of Google Analytics by using the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

 

Most browsers are initially set to accept Cookies. However, you have the ability to modify the usage of or disable Cookies if you wish, generally through changing your internet software browsing settings. 

Note: if Cookies are disabled, it may mean that you experience reduced functionality or you may be prevented from using elements of the Crown website altogether.

 

14. Retention

Crown will retain your personal information for the purposes set out in this Policy, and to the extent permitted by law for backup, fraud prevention or detection, or audit purposes. Crown will also retain and process your personal information to the extent necessary to comply with Crown’s legal obligations (for example, if Crown is required to retain your personal information to comply with applicable laws), resolve disputes and enforce Crown’s legal agreements and policies.

If you no longer wish to be Crown’s customer, or cease using or accessing Crown’s services, you can request to delete your personal information by contacting Crown as per the details provided under the “Contact Crown” heading below. While your account may have been deleted as per your request, Crown may still retain your personal information, if necessary, as described in the first paragraph of this Section 14.

15. Changes to this Policy

Crown may change or update this Policy from time to time. Any changes to this Privacy Policy will be posted to this page and will come into effect on the date of posting. Where consent is a legal basis, Crown will give you the opportunity to decide as to whether you would like to grant your consent for the processing of your personal information by Crown for different or new purposes, prior to the processing of your personal information for such new purposes.

16. Contact Crown

If there are any questions regarding the Crown Privacy Policy or the way that Crown manages personal information or if there are any concerns about Crown’s treatment of personal information, then Crown may be contacted by post, telephone or email:

Crown Data Protection Officer
222 / 6-7 Moo 5, Baan Rakard,
Bangboa, SamutPrakarn 10560
Telephone: (66) 2118 3222
Email: privacy.th@crown.com