Isuzu Motors Company (Thailand) Limited
Privacy Notice for Shareholders and Directors
Dated 12 May 2022
This Privacy Notice for Shareholders and Directors (the “Privacy Notice“) is made by Isuzu Motors Company (Thailand) Limited (the “Company“) as the Company realize the importance of your personal data (as defined below). This Privacy Notice is issued to describe how the Company collects, uses, and discloses (collectively referred to as “processes“) your personal data, as you are either former or current shareholder, director, or shareholder or director of the Company’s shareholder who is an entity (“you“). The Company works to ensure that all of the Company’s personnel process data strictly in accordance with this Privacy Notice.
This Privacy Notice applies to all communication channels, online and offline, including face-to-face communication, telephone communication, and other means of communication, unless a specific privacy notice applies.
The Company may amend this Privacy Notice in the future to ensure its alignment with changes in laws and our own practices. If consent from you is required for data processing under the Privacy Notice, as modified or amended, the Company will ask for your prior consent.
A. Personal data
The Company collects your personal data that you have provided to the Company, or as the Company have obtained from other sources, including company certification documents, lists of shareholders, Ministry of Commerce, vendor, and other third parties. Personal data includes, but is not limited to, the following.
- Personally identifiable information
Name, surname, age, date of birth, work information, job title, signature, voice record which is not voice recognition data, car registration number, bank account information, photographs, video, information on the national identification card, passport information, work permit information, visa information, driver’s license information, information in other identification documents issued by government agencies (except for sensitive data), and other information that can be used to verify your identity (collectively referred to as “personally identifiable information“).
Other information which is necessary for inspection of conflict of interest, i.e., information concerning your shareholding in business entities, relationship with business partners, membership of association or organization established under the law.
- Contact information
Personal or work phone number, mobile phone number, fax number, address, and email address(collectively referred to as “contact information“).
- Security information
- Sensitive data
Religion, race and blood group (collectively referred to as “sensitive data“). Normally, the Company has no intention to process your sensitive data, but it appears on your identification documents, including your national identification card or passport. Therefore, the Company may conceal, or ask you to conceal, your sensitive data that appears in those documents to prevent us from unnecessarily collecting your sensitive data.
The Company processes your personal data for the purposes provided below, and on legal bases, including legal obligations, contractual obligations, our legitimate interests, or your consent. If the Company processes your personal data on the basis of your consent, you may withdraw your consent at any time, in accordance with clauses G and H below. However, the withdrawal will not apply to the processing of your personal data that the Company carried out with your consent before such withdrawal.
Your personal data is necessary for the purposes provided below. Otherwise, the Company may not be able to perform our obligations under applicable laws or agreements the Company has with you. In certain limited cases, you may not be able to receive the relevant compensation, such as dividend for shareholders or remuneration for directors (if any). The purposes for the data processing include, but is not limited to, the following (hereinafter referred to as the “Purposes“).
- Purpose of business proceeding
Your personally identifiable information will be processed on the legal obligation basis in order that the Company can hold the shareholders meeting, directors meeting, proceed with any registrations for the Company, preparing share registration book, share certificates, list of shareholders, list of directors, or other documents to be submitted to the relevant authorities according to the law or the official’s order in order to comply with the law, labour protection law, civil and commercial law, and proceed with other proceeding as required by laws.
- Purpose of business operations
Your personally identifiable information and your contact information will be processed on the legal obligation basis, the contractual obligation basis, and the basis of our legitimate interest in order that the Company will be able to improve our business operations, signing, audit our accounts, supervise and ensure our compliance, establish and enforce our terms and conditions, conduct our internal management, respond to complaints and conduct internal investigations, prepare the organizational chart, take part in business transactions with our dealers, customers, and clients, and carry out operations in the ordinary course of the Company’s business.
- Purpose of your interest
Your personally identifiable information and your contact information will be processed on the legal obligation basis and the contractual obligation basis in order that the Company can pay compensation for you, such as dividend or director remuneration, provide benefit, such as travel, accommodation, golf club membership, or other welfare agreed with the Company or to be provided by the Company (if any).
- Purpose of informing
Your personally identifiable information and your contact information will be processed on the contractual obligation basis, and the basis of our legitimate interest, in order that the Company can communicate our messages, answer questions, respond to opinions and feedback, and send documents about you.
- Purpose of security
Your personally identifiable information, contact information, and security information will be processed on the legitimate interest basis to maintain our safety and security, verify your identity, and keep records and evidence.
C. Data storage and security standards
The Company carefully store your personal data, with physical and electronic security measures, to prevent your personal data from accidental loss, or unauthorized use, access, damage, destruction, modification, or disclosure. Physical measures include restrictions of access by those granted access to information, storing your personal data in locked cabinets, and control over access to data storage premises. Electronic measures include restrictions of access by those granted access to information. If there is an incident involving the security of personal data, the Company will solve the issue immediately.
D. Retention period
Your personal data will be retained only for as long as necessary and reasonable to achieve the aforementioned Purposes, or for possible future prescriptions. Certain personal data may appear in the share registration book or company certification document as long as the Company still operates. In the event of legal proceedings, including appeals, your personal data may be retained until the process is completed. After that, your personal data will be deleted or destroyed, or retained only as required by applicable law.
E. Disclosure of personal data
For the Purposes given above, the Company may disclose your personal data to third parties, including our parent company, subsidiaries, group or affiliated companies, dealers and business partners, services providers, contractors, advisors, auditors, banks, competent government agencies, such as the Ministry of Commerce, the Ministry of Labour, and the Ministry of Industry, among others, and other third parties in public and private sector agencies. The Company will use reasonable efforts to ensure that the recipient of your personal data has sufficient personal data security measures as required under applicable law.
In the case of sale or transfer of the Company’s business or assets, in whole or in part, such as through acquisition, merger, consortium, or joint venture, the Company may disclose your personal data to those involved in these activities.
F. Cross-border transfer of personal data
The Company may disclose your personal data to overseas recipients for the aforementioned Purposes from time to time. In this case, the Company will use reasonable efforts to ensure that the disclosure complies with applicable law.
G. Your rights
You, as the data subject, have the following rights regarding your personal data. If you wish to exercise any of the rights, please contact us as provided in clause H. For security purposes, and for your privacy, the Company may ask you to verify your identity before proceeding with your request.
- Right to access
You have the right to access, or request copies of your personal data. However, the Company will allow you to access only your personal data, not the entire documents.
- Right to rectification
You have the right to rectify your personal data that is incomplete, inaccurate, misleading, or outdated.
- Right to data portability
You have the right to request your personal data, or that the Company transfer your personal data to other data controllers, if that personal data is processed on the basis of consent or contractual obligations.
- Right to objection
You have the right to object to the processing of your personal data in some cases, such as direct marketing.
- Right to deletion
You have the right to request that the Company delete, destroy, or anonymize your personal data in some cases, for example if the personal data is no longer necessary for processing for any purpose, or that personal data was unlawfully obtained.
- Right to restrict the use of data
You have the right to request the restriction of the use of your personal data in some cases, such as when the Company are considering your objection request, or when you request that your personal data be used with restriction instead of being deleted.
- Right to revoke your consent
You may revoke the consent you have provided to us at any time. However, the revocation will not apply to the processing of your personal data that the Company carried out before the revocation.
- Right to complaint
If you consider that the Company fail to comply with applicable law, you may make complaints to data protection authority under applicable law.
If you have any question or inquiry, or if you wish to exercise any of your rights regarding your personal data, please refer to the contact information below.
Contact information: Legal Department
Isuzu Motors Co., (Thailand) Ltd.
38 Kor., Moo 9, Poochaosamingprai Rd., Samrongtai, Phrapradaeng, Samutprakarn 10130