Privacy Policy

Privacy Policy

INTRODUCTION

Welcome to the Franco-Thai Chamber of Commerce privacy notice.

The Franco-Thai Chamber of Commerce (FTCC) respects your privacy and is committed to protecting your personal date. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims at giving you information on how the Franco-Thai Chamber of Commerce collects and processes your personal data (including through your use of this website).

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, so please read it carefully. By using our services, participating as a member or attending our events, either by registering online or providing your details at our event, you hereby consent to your information being processed by us in the manner described in this Privacy Policy and pursuant to the Personal Data Protection Act of Thailand.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Identity of the controller

The Franco-Thai Chamber of Commerce is the controller and responsible for your personal data (collectively referred to as FTCC, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any question about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

Contact details :

Full name of legal entity : the Franco-Thai Chamber of Commerce

Name or title of Data Protection Officer: Mrs. Justine De Guerre, Executive Director

Email address : Justine(@)francothaicc.com

You have the right to make a complaint at any time to the relevant authorities. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authorities so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual form which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

If you are a visitor to the Site or potential member:

• First name
• Last name
• Email address
• Job title
• Company name
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

If you are a FTCC member or client:

• Identity Data includes first name, last name, username or similar identifier, job title, title
• Contact Data includes billing address, correspondence address, email address and telephone numbers
• Regulatory Data includes relevant information as required by regulatory Know Your Client or Anti Money Laundering regulations. (HMRC)
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and communications Data includes your preferences in receiving marketing from us and your communication preferences.

If you are a candidate using our recruitment service:

• Identity Data includes first name, last name, username or similar identifier, job title, title.
• Contact Data includes correspondence address, email address and telephone numbers
• Curriculum vitae
• References from former employers if you are a candidate, you accept, by posting your CV and other personal information online that this data appears on our website and that it might be visible to all visitors, or even on other websites, including but not limited to search engines. Since this data was voluntarily provided, posted and published by candidates, we do not control the content of this information, its accuracy or its veracity. We also do not take the decision of deleting this information from our website without the full consent or an official written request from the candidates. We shall not be held responsible if the information provided by a candidate remain visible on our website and subsequently on other websites, even becoming obsolete.

Sensitive data

We do not collect any data known as “sensitive”. That is, data relating to racial or ethnic origin, political, philosophical or religious opinions, trade union membership, health or sexual orientation.

Information about other people

If you provide information to us about any person other than yourself, your employees, your referees, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

• Apply for Membeship;
• Apply for our products or services;
• Create an account on our website;
• Subscribe to our services or publications;
• Register as a candidate for recruitment services on our website;
• Request marketing to be sent to you; or
• Give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

We use “cookies” on our website to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and enables us to improve our website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

• If you are a candidate using our recruitment service, we may also collect Personal Data from third parties, such as LinkedIn and references from former employers.

4. HOW WE USE YOUR PERSONAL DATA ?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where we need to carry out requests made by you on the website or in relation to our services
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation;
• Where we provide support for the provision of our services, including the promotion of our Members on our website and in our communications.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data (depending on your relationship with the Chamber), and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds on which we are relying to process your personal data where more than one ground has been set out in the table below

Members

Types of data : Identity, Contact, Profile, Position, Job Title, Presentation of company and activities, Financial and banking information, other information provided by you when applying for Membership and late on while still a FTCC Member.

It is reasonable to expect that if you have applied to become FTCC Member, have filled in all the requested information, have sent other files and information, and have agreed, at the end of the Membership Application Form that the FTCC will use this data to promote you as a Member in its communications (website, Membership Directory, introductions to contacts…) and as part of its services, you consent to us collecting and otherwise use your personal data to offer or provide our services to Members, as described on our Website, in our Catalogue of Services, in our Membership Application Form, in our emailing campaigns, during our Annual General Meeting, and in any other support published by the FTCC.

Candidates

Types of data: Identity, Contact, Curriculum Vitae, References

It is reasonable to expect that if you have sent us your Curriculum Vitae and personal information or uploaded them to our website you consent to us collecting and otherwise use your personal data to offer or provide our recruitment services to you and share that information with prospective employers (members and/or clients).

Marketing

We need your consent for some aspects of these activities which are not covered by our legitimate interests (the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we will ask for this via an opt-in or soft-opt-in (which we explain further below).

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by virtue of your membership, attending a Chamber event). Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. You can opt out at any time by clicking on the unsubscribe button present in all our communications.

For other types of e-marketing, we are required to obtain your explicit consent.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside FTCC for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or following the opt-out links on any marketing message sent to you at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data (depending on your relationship with the Chamber) with the parties set out below for the purposes set out in the table above.

• External Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• In relation to candidates using our recruitment services, we will share your personal data with potential employers.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The security of your information is important to us. We maintain appropriate and reasonable security arrangements to prevent unauthorized access, collection, use,  disclosure, copying, modification, disposal or similar risks. The transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information provided to us  via the internet, and any transmission is at your own risk.

7. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you want to learn more about our specific retention periods for your personal data established in our retention policy you may contact us at Contact(@)francothaicc.com

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Deny, suspend or withdraw consent: The right to object to any collection, use, or disclosure of personal data at any time.

Update and Access: The right to update and ask for a copy of your personal information and disclose where we obtained it.

Deletion: The right to ask us to delete personal information at any time.

Data format : The right to obtain the data in commonly used machine-readable format.

If you wish to exercise any of the rights set out above, please contact Data Protection Officer.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to our privacy policies

The French Chamber of Commerce in Thailand can update its confidentiality commitment periodically. In the event of a substantial change, a notice will be posted on our website, accompanied by a link to our updated privacy policy.

Version updated in : May 2022