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NETWORK ADVISORY TEAM LTD.

This CCTV Privacy Policy (“Policy”) is to inform you about Network Advisory Team Ltd. (hereinafter referred to as “NAT”, “we”, “our” or “us”) use of closed-circuit television (CCTV) devices to monitor within or around our premise, building, other of our facilities and/or event areas and/or showroom and/or other areas relating to NAT business, in order to protect life, health and property. We collect personal data of all employees, directors, contractors, workers, visitors, customer or any individuals entering the monitored space within our buildings and facilities (collectively referred to as “you” or “your”) through the use of CCTV devices. This Policy provides information on our collection, use, disclosure, and/ or cross-border transfer of individually identifiable information (“Personal Data”) about you.

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NAT reserves the right to amend this Policy at any time, in its sole discretion, to modify, revise, delete and update this Policy. NAT will use reasonable endeavors to notify you in appropriate manner of any modification to the terms of this Policy. 

1. Personal Data collected

NAT collects your stills and moving footages, images, and/or voice which may include your belonging e.g., vehicles, or other identifiable source of information as observable by the CCTV footages, when entering the monitored space in our buildings and facilities through the CCTV devices.

2. Why we collect, use and/or disclose your Personal Data

2.1 We will not collect, use, disclose, transfer, and carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, or adding, your Personal Data concerning you, for the purposes as listed below (“CCTV Monitoring Purposes”) without your consent, except for the following:

(1) Vital interest: it is to prevent, protect and/or suppress a danger to a person’s life, body and health, such as to protect your health and personal safety, including your belongings; 

(2) Legitimate interest: it is in our legitimate interest: (1) to protect your health and personal safety, as well as your belongings, our buildings, facilities and assets from damage, disruption, vandalism, and other crime, (2) to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings, (3) to assist in the investigation or proceedings concerning a whistleblowing complaint, (4) to assist in the establishment or defense of any litigation, including but not limited to employment proceedings, and (5) to carry out any other acts to achieve the CCTV Monitoring Purposes. 

We will endeavor on the continuing basis to balance our legitimate interest and that of any relevant third parties, as the case maybe, and your fundamental rights and freedoms related to the protection of the Personal Data concerning you. We will also endeavor to identify any steps required to achieve the right balance as appropriate; and 

(3) Legal obligation: it is to comply with applicable legal obligation, cooperating with governmental authorities, governmental agency, and law enforcement authority, including but not limited to the laws regarding safety and environment in the workplace. We consider the use of the CCTV as a necessary measure to enable us to meet those obligations, such as to support law enforcement organizations in the deterrent, prevention, detection, and prosecution of crime.

2.2 We will install CCTV devices in plain sight.

2.3 Our CCTV devices are in operation 24 hours a day and 365 days a year, and will capture without audio recordings.

3. To whom we may disclose or transfer your Personal Data

3.1 We will keep your Personal Data confidential and will not disclose or transfer it except to our subsidiaries, affiliates, and other carefully selected third parties now or in the future.

3.2 We may disclose your Personal Data in order to achieve the purposes set forth in this Policy. The parties to which we may disclose your Personal Data to includes, but is not limited to:

(1) Our affiliates: We may disclose or transfer Personal Data concerning you to our affiliated companies, as part of our legitimate interest and our affiliates' interest to achieve the CCTV Monitoring Purposes.

(2) Governmental and/or regulatory organizations: We may disclose or transfer Personal Data concerning you to comply with legal obligations, or to support or assist law enforcement organizations with regard to the investigation and prosecution of civil or criminal or administrative proceedings.

(3) Third-party: We may disclose or transfer Personal Data concerning you as our necessary steps to ensure our protection of your health and personal safety, and belongings.

4. Security

4.1 We use reasonable organizational, technical, and administrative security measures to protect Personal Data concerning you from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure.

4.2 We will from time-to-time review and update our security measures as necessary or upon development of the concerning technology to ensure effective and appropriate security measures, and in line with minimum legal requirements as prescribed by the relevant governmental organizations.

5. How long do we keep your Personal Data

NAT will only retain your Personal Data for as long as reasonably necessary to fulfil our duties to achieve the CCTV Monitoring Purposes prescribed in this Policy. If a judicial or disciplinary action is initiated, your Personal Data may be stored until the end of such action, including any potential period for appeal, and will then be deleted or archived as permitted by applicable laws.

6. Your rights as a data subject

Under some circumstances, we may require you to prove your identity before complying with data subject exercise of rights, for your own privacy and security. 

Subject to Applicable Laws and exceptions thereof, you may have the following rights to:

(1) Access: You may have the right to access or request a copy of the Personal Data we are collecting, using and disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you. 

(2) Rectification:  You may have the right to request for rectification of the incomplete, inaccurate, misleading, or not up-to-date Personal Data that we collect, use, store, disclose and/or cross-border transfer.

(3) Data Portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing such data on the basis of your consent or to perform a contract with you.  

(4) Objection: You may have the right to object to certain collection, use and disclosure of your Personal Data. 

(5) Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances. 

(6) Withdraw Consent: For the purposes you have consented to our collecting, using and disclosing of your Personal Data, you have the right to withdraw your consent.

(7) Deletion: You may have the right to request that we delete or de-identity Personal Data that we collect, use and disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.

(8) Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.

7. Our Contact Details

If you wish to exercise your rights above, or if you have any queries, comments and/or questions about your Personal Data under this Policy, please contact us at:

(1) NAT Call Center
• Address: 1111/104 Baan Klang Muang, Ladprao Rd., Chankasem, Jatujak Bangkok 10900
• Contact Details:

o Phone number: 02-513-7151 (Available every day except National Holidays from 8:00 a.m. to 05:00 p.m.)
o Email address: info@thaiaccounting.com

(2) Data Protection Officer (DPO)
• Address: 1111/104 Baan Klang Muang, Ladprao Rd., Chankasem, Jatujak Bangkok 10900
• Contact Details
o Email address: info@thaiaccounting.com

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