Bhiraj Buri Group (“BBG” or “us”) respects and values the privacy and confidentiality of your personal data and commits, with our best effort, to protect all personal data for its security and confidentiality. BBG will collect, retain, use and disclose your personal data pursuant to this Privacy Policy (“Privacy Policy”) which is in compliance with the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) and other applicable laws.

You should review this Privacy Policy together with privacy statements which BBG additionally prepare for each type of relevant data subjects who are relating to BBG, which are (i) Customers, (ii) Vendors, (iii) Employees and (iv) Unit holders (collectively, “Privacy Statements”). This Privacy Policy supplements to the Privacy Statements. The content provided herein does not and will not cancel, replace, or override any provision in the Privacy Statements. If there is any conflict between the two documents, the Privacy Statements shall prevail.

• Types of Personal Data
  
  • “Personal Data” means any data relating to an individual which can identify such individual, directly or indirectly, excluding the data of a deceased individual or any other data specified by the PDPA.
  • BBG may collect your Personal Data as follows:
  • Identity data such as name, family name, nickname, gender, age, date of birth, nationality, still image, video recording, identification number or passport number, marital status, job position, name of your employer, license plate number, information of your related person such as family member and/or any other data with the similar nature;
  • Sensitive data such as facial scan, fingerprint scan, medical examination result, ethnicity and health data;
  • Contact details such as address pursuant to the identification card, phone number, email, details about the social application i.e., Line ID, Facebook account and any other data with the similar nature;
  • Membership data such as membership number, membership type, subscription date and expiration date;
  • Data in relation to a holding of units in the Bhiraj Office Leasehold Real Estate Investment Trust (“BOFFICE”) such as unit holder registration number, unit holding information, and Thailand Securities Depository (TSD) registration number;
  • Employee data such as position, salary rate and other remuneration, benefits and welfare under the employment agreement, reimbursement record, attendance record, performance assessment record and other records, compliant filing record, investigation and disciplinary records;
  • Financial data such as information in relation to the investment in BOFFICE, bank account number, type of bank account, payment amount, tax information, tax deduction and expense, and transaction details relating to your transaction with us;
  • Preference data such as your satisfaction and comment on our goods and services;
  • Qualification data such as educational information, work experience, skills and expertise, profession-related license and other data with the similar nature;
  • Security & loss prevention data such as security camera footage and other data which can be used to maintain BBG’s security; and
  • IT Data such as IP address, cookies, and other technical information data with the similar nature.
    If you would like to work with us, become our member, or engage in activity or business with us, we need to collect your Personal Data. If you do not provide Personal Data which is necessary and required to proceed with the relevant activities or transactions to us, we may not be able to enter into a contract with you, proceed with certain matter requested by you, perform our contractual obligations or comply with the applicable laws which we have to comply.
    If you provide the Personal Data of other individual to us, you confirm that such individual has reviewed this Privacy Policy and that such individual has given his/her consent regarding the processing of their Personal Data pursuant to this Privacy Policy. You are required to present and deliver the consent form of such persons to us upon our request.
    For the Personal Data collected before 1 June 2022, BBG will proceed with such Personal Data in accordance with the PDPA. Nevertheless, for any Personal Data which is required to be collected, used or disclosed only with your consent pursuant to the PDPA, if you would like us to stop retaining, using or disclosing of such Personal Data, you may request to withdraw your consent at any time by contacting BBG or our data protection officer (DPO) as detailed in Paragraph 15 below.
• Collection of the Personal Data
  
  • BBG may collect the Personal Data provided by you directly from you or by other channels as follows:
  • Website Usage: BBG may collect your Personal Data when you use our website and our application by Cookies and other similar technologies. We also collect those data when you use our service or access our internet network and our social media, such as, Facebook, Instagram, Twitter or Line official.
  • Related Person: BBG may collect your Personal Data through your assigned coordinator, secretary, contact person or other person which has relationship with you, such as, your attorney, legal representative, family member, reference person or another person who worked with you.
  • Related Company/ Organization: such as, the organization you work for (i.e. your employer) or have relationship with, including our business partner which may be your vendor or service provider.
  • Public Sources: BBG may collect your Personal Data from public sources, such as, government agency, state enterprise, regulator, as well as public website and/or social media.
• Retention Period
  
  • BBG will retain the Personal Data as necessarily required to achieve the purposes as specified in this Privacy Policy, the details of the retention period for the relevant Personal Data are specified in the Privacy Statements.
  • However, BBG may continue to retain the Personal Data as long as (a) it is permitted by the PDPA and/or other applicable laws, (b) you and BBG continue to have an on-going legal relationship with each other, (c) BBG is required to retain the Personal Data under any laws or regulations, (d) the consent granted to BBG by you has not been revoked and (e) it is deemed necessary to complete the purposes specified in this Privacy Policy.
• Purposes of Personal Data Processing
  
  • Your Personal Data shall be collected and used only for the purposes stated below, including those purposes stated in the Privacy Statements, or the purposed for which you have given your consents, and any other purposes as permitted or required in the PDPA and/or any applicable laws.
  • Legal Obligation

    	(1)	To arrange BOFFICE’s unit holder meeting, to prepare relevant documents such as the report of unit distribution, to review related party transaction and to proceed with tax-related matters
    	(2)	To run BOFFICE’s operation, including the dividend distribution, capital increase, the issuance and allotment of debentures.
    	(3)	To comply with legal requirements such as the PDPA, Civil and Commercial Code in the part applicable to BBG, Revenue Code, Accounting Act B.E. 2543 (2000), Labor Protection Act B.E. 2541 (1998), Social Security Act B.E. 2533 (1990), Compensation Act B.E. 2537 (1994), Occupational Safety, Health and Environment Act B.E. 2554 (2011), Communicable Diseases Act B.E. 2558 (2015), Ministerial Regulation on the Prescribing of Criteria and Method of Conducting Health Checkup of Employees and Forwarding the Results of Health Check up to Labor Inspectors B.E. 2547 (2004) and the Notification issued by the Securities and Exchange Commission (SEC)
    	(4)	To comply with court orders

  • Contractual Basis

    	(1)	To proceed with your request before entering into contract with you, such as, assess, evaluate and select the employees or vendors whom BBG will engage with
    	(2)	To enter into any agreement or transaction with you, as well as to comply with any contractual obligations between BBG and its customers, vendors, personnel or any other person which includes but not limited to the following activities: a co-ordination between parties, the assignment of contractual obligations, the payment or the request for payment
    	(3)	To proceed with activities relating to your membership with BBG such as a registration of membership, membership payment, a preparation and delivery of a membership card as well as a renewal of membership.

  • Legitimate Interest

    	(1)	To recruit potential person to work with BBG
    	(2)	To distribute any still images and/or video recordings of our activities for any public relations purpose for our goods and services any marketing promotion on websites and social media platforms of BBG or as controlled by BBG, which is not considered as the targeted advertisement
    	(3)	To conduct market analysis and market research to improve our goods and services, as well as other activities
    	(4)	To verify the identity of customers or vendors prior to the execution of contract or the performance of obligations thereunder
    	(5)	To collect corporation’s representative data, including to communicate with corporate customers or vendors through such representative, such as, to confirm the payment, to request for comment and opinion and to coordinate for transaction between you and us
    	(6)	To inspect, record and prepare an area access control register, an exchange of access card to the building or restricted area including a proceeding in case there is a loss of parking ticket/card
    	(7)	To comply with your request to access surveillance cameras
    	(8)	To review the permit, consent or the documents evidencing the compliance of applicable laws relating to the security preservation
    	(9)	To prevent, handle and manage potential risk, to investigate internal operation of BBG, as well as to conduct internal audit and to engage with legal, account or tax advisors in relevant matters
    	(10)	To proceed with human resources related matter, such as, a retention and use of data of the applicants for potential recruitment in the future, as well as for BBG’s management and development of the human resources related works.
    	(11)	To preserve and maintain BBG’s security and IT security, to prevent accidents and deter crimes, as well as to investigate any act which may be in violation of law or causing any potential harms
    	(12)	To disclose data to a company in the BBG which is deemed necessary to comply with our agreement with you or pursuant to your instructions, as well as to conduct internal audit and internal coordination as necessarily required for our business operation

  • Consent

    	(1)	To verify sensitive data in relation to your medical examination result to ensure compliance with law, in case you are the service provider who are in contact with foods that is sold in our area
    	(2)	To collect and record the information of your facial scan and/or fingerprint scan to grant authorization to enter specific area and to record time of entrance and exit
    	(3)	To notify the emergency alert or other threats in or nearby BBG’s area which may cause life, body or health injury
    	(4)	To advertise goods and services as well as promotion in which you may be interested (Direct Marketing)
    	(5)	To deliver birthday greeting to you as our valued customer as for good relationship between you and BBG
    	(6)	To proceed with human resources related matter involving sensitive data, such as, medical examination, health insurance and other welfare related to health
    	(7)	To confirm your employee status with third party, such as, financial institution or your new employer, as well as to proceed and comply with your request after the termination of your employment
    	(8)	To process the sensitive data, such as, to proceed with your request of medical fee advancement or reimbursement and to keep such request as evidence

• A Recipient of Personal Data disclosed by BBG
  
  • In accordance with the purposes specified in this Privacy Policy, Privacy Statement and Consent Form, and as permitted or required in the PDPA and/or any applicable laws, your Personal Data may be disclosed or transferred to third parties and/or government agency as elaborated below.
  • Speaker or lecturer, as well as the person joining the training, lecture, seminar and any other BBG’s event
  • General public or those who visit website, social media platforms and social applications of BBG
  • Government agency and state enterprise, such as, Revenue Department, TOT Public Company Limited, Stock Exchange of Thailand and the Securities and Exchange Commission
  • Financial institution, such as, the bank providing financial services to you, the bank providing financial services to BBG and the provident fund
  • Trustee or any other person engaged in business with BOFFICE’s trustee
  • Insurance Company, including its broker and other vendors and services providers
  • Service providers, vendors, suppliers, contractors and sub-contractors who are working with us to supply and provide goods and services to us, such as, media agency, IT service provider, website and software services provider, airlines and hotels, travel agents, delivery company, market analysis and research company, payroll company, event organizer, including catering company or other service providers
  • Professional advisors, such as, accountant, attorney, legal adviser, auditor and internal auditor
  • Your related person, such as, contact person, coordinator, including your family member
• Cross-Border Transfer of Personal Data
  
  • BBG may disclose or transfer your Personal Data to a recipient outside Thailand (if any), such as, BBG’s sponsors or the entity which arranging and organizing any event with BBG. In any case, such transfer will be limited and proceeded as necessarily required for the purposes specified in this Privacy Policy and Privacy Statement. BBG will implement appropriate and necessary security measures for the transfer of Personal Data to the recipient outside Thailand, such as, the assessment of recipient’s accountability and Personal Data protection measures of the recipient or the execution of confidentiality agreement with the recipient.
  • In the event that the destination countries do not have the sufficient data protection standards, BBG will ensure that the transfer of your Personal Data will be in accordance with the PDPA or other applicable laws.
• Cookies
  
  • Cookies are pieces of information which are sent from our website to your browser when you are visiting our websites, in order to collect your log files, such as your language preference, system user, or other settings. BBG may collect cookies or other similar information when you interact with or proceed the transaction with BBG via internet system, including when you are visiting the websites of BBG or as controlled by BBG.
  • Cookies and the similar technologies have no side effects which may harm your computer. BBG may use cookies and other similar technologies for below purposes with your consent.
  • To allow the users to access or use services or functions in BBG’s websites and applications
  • To increase effectiveness of the BBG’s websites and applications in operating online service or interactive applications
  • To help BBG recognize and respond to your request more effectively, such as, to recognize a name, account, password or previous setting preference for your next visit
  • To analyze, enhance, and develop website performance
  • To conduct direct marketing and market research
    You may delete or deactivate cookies by entering www.bhirajburi.co.th. If you delete or deactivate cookies, you may not be able to smoothly use some or all of our services.
• Minors, Incompetent Persons or Quasi-Incompetent Persons
  
  • For any processing of Personal Data of minors for the purpose which the minor alone cannot authorized or executed by him/herself as specified under the Civil and Commercial Code, BBG will request for a consent from the legal representative of the minor before collecting the Personal Data. Kindly be informed that a minor of age 10 and below, the consent from the legal representative is required before a collection of Personal Data in every case.
  • For any processing of Personal Data of an incompetent person, the consent from his/her custodian is required in every case.
  • For any processing of Personal Data of a quasi-incompetent person, the consent from his/her curator is required in every case.
  • BBG is unable to verify or identify the legal status of the visitor to our website, whether the visitor is a minor, incompetent person or quasi-incompetent person. We have no intention to collection Personal Data or information of such persons to proceed with any activities. If we later find out that we obtain any Personal Data from the minor, competent person, or quasi-competent person, we will proceed to request for consent from their legal representative, guardian, or curator (as a case may be) before proceeding further with their Personal Data.
• Surveillance camera
  
  • BBG uses surveillance cameras to record activities and persons who accessing into or passing by the BBG’s areas in order to maintain and preserve our security, prevent any accident and danger as well as to for an investigation of crime. BBG ensures that live feeds and captures from the surveillance cameras will be observed by authorized person only.
• Personal Data Related Measures and Policies
  
  • BBG recognizes the importance of the compliance with PDPA. Therefore, in order to maintain and preserve the security of your Personal Data, we implement below measures and policies to secure your Personal Data
  • Business Continuity Policy
  • Disclosure of Information Policy
  • Intra-group Data Sharing Policy
• Data Subjects’ Rights
  
  • You are entitled to the rights stipulated in the PDPA, which are subject to the conditions prescribed in the PDPA and other laws related to such rights. [BBG prepared the Data Subject Request Form and uploaded to our website at www.bhirajburi.co.th for you to access and use such Data Subject Request Form to exercise your rights, as the data subject, under the conditions specified in the PDPA and applicable laws].
  • Right to Access: You have the right to access or request a copy of your Personal Data, which BBG is collecting, using or disclosing, including to disclose the acquisition method of your Personal Data which BBG obtained without your consent.
  • Right to Data Portability: You have the right to obtain your Personal Data, provided that BBG has arranged such Personal Data in the format which is readable or commonly used by ways of electronic tools or equipment and can be used or disclosed by automated means. You have the rights to request BBG to transfer your Personal Data to third party or receive the Personal Data which BBG has transferred to third party, unless it is impossible to do so because of the technical circumstances, provided that such requested Personal Data must be collected, used, or disclosed by BBG pursuant to your consent, or under contractual basis, or other criteria prescribed by law.
  • Right to Objection: You have the right to object the collection, use, and disclosure of your Personal Data in the event that BBG processing your Personal Data with any of the following basis: the public interest, legitimate interest, or for the direct marketing purposes or for the scientific, historic or statistic research purpose.
  • Right to Deletion: You have the right to request BBG to delete or destroy your Personal Data or to anonymize your Personal Data for certain reasons.
  • Right to Restrict Processing: You have the right to request BBG to restrict the processing of your Personal Data during BBG’s considering your request either to rectify your Personal Data or objection to our processing of your Personal Data, or restrict a processing of your Personal data instead of deletion or destroying of your Personal Data in a case where your Personal Data is no longer needed but you have specifically requested for BBG to keep your Personal Data for a purpose of establishing any legal entitlement, compliance to the laws, making any demands or requests or to use it as argument against any claim.
  • Right to Rectification: You have the right to request us to rectify your Personal Data to be accurate, up to date and not misleading.
  • Right to File a Complaint: You have the right to file a complaint with the Personal Data Protection Committee if we, our employees or our contractors violate or do not comply with the PDPA.
  • Right to Withdraw Consent: You have the right to withdraw your consent at any time, whether for some or all purposes, by follow our determined procedure and method. Nevertheless, your consent withdrawal shall not affect the collection, use and disclosure of Personal Data which you have consented us to proceed prior to such withdrawal.
    You may exercise these rights by contacting BBG or our data protection officer (DPO) as detailed in Paragraph 15 below.
    In the event that your consent withdrawal will affect you in any manner, we will inform you of such consequences. In case you withdraw your consent, such withdrawal shall not affect the collection, use and disclosure of Personal Data which we have already conducted by your consent.
    For your interests which we concern, together with our commitment to secure your Personal Data , BBG may refuse to comply with your request in the event that (a) the person submitting the request cannot prove that he/she is the data subject or does not have the authority to submit such request, (b) the request is not reasonable, such as, the person submitting the request does not have the rights under the PDPA or there is no Personal Data of such person in BBG’s possession, (c) the request is excessive or vexatious, such as, the request unreasonably repeats a previous request (d) BBG has compelling legitimate grounds to reject such request as required or permitted by the PDPA and/or any applicable laws.
• Privacy Policy of Third-Party Websites
  
  • This Privacy Policy applies only to BBG’s activities. Our websites and applications may contain link which may bring you to another websites or applications. If you enter the linked websites or applications, it is suggested that you carefully review the privacy policies of such websites or applications, which are separate from ours, before submitting or giving your Personal Data. BBG shall not be responsible for any processing of Personal Data, or the use of cookies conducted by the linked websites that you access from our website.
• Amendment and Review
  
  • BBG may regularly review this Privacy Policy from time to time to be in accordance with any amendments made to the PDPA and applicable laws, or when there is any change to technology to ensure security. Amendments to this Privacy Policy will be publicly announced on BBG’s websites in timely manners.
• Miscellaneous
  
  • This Privacy Policy are governed by and shall be construed in compliance with the PDPA and the laws of Thailand.
• Contact Us
  
  • Regarding all queries or awareness with respect to the Personal Data arising from this Privacy Policy, or the activities of BBG, including the exercise of any rights as set out in Paragraph 11, please contact us and our data protection officer at below address:
  • BBG group companies

  No.	Name
  1.	BHIRAJ BURI HOLDING COMPANY LIMITED
  2.	ABOUT FOOD COMPANY LIMITED
  3.	BANGKOK INTERNATIONAL TRADE & EXHIBITION CENTRE COMPANY LIMITED
  4.	BHIRAJ BURI COMPANY LIMITED
  5.	BHIRAJ MANAGEMENT COMPANY LIMITED
  6.	BHIRAJ MASTER PLAN COMPANY LIMITED
  7.	BHIRAJ SERVICES COMPANY LIMITED
  8.	BHIRAJ TOTAL SOLUTIONS COMPANY LIMITED
  9.	BHUMI BANGCHAK COMPANY LIMITED
  10.	BHUMI LASALLE COMPANY LIMITED
  11.	BHUMI NAVA COMPANY LIMITED
  12.	BHUMI SAMING COMPANY LIMITED
  13.	BITEC MANAGEMENT COMPANY LIMITED
  14.	BITEC SERVICES COMPANY LIMITED
  15.	KURA BURI COMPANY LIMITED
  16.	MOOK AND MORE COMPANY LIMITED
  17.	PENTA 591 COMPANY LIMITED
  18.	PHARINDHORN COMPANY LIMITED
  19.	PHATRA BURI COMPANY LIMITED
  20.	SINSANPHAWUT COMPANY LIMITED
  21.	BHIRAJ REIT MANAGEMENT COMPANY LIMITED
  22.	BHIRAJ AND BEYOUND VENTURES COMPANY LIMITED
  23.	BHIRAJ ASSET 23 COMPANY LIMITED
  24.	Other Companies which may be established in the future (which will be informed accordingly)

  • Data Protection Officer
  • To: BHIRAJ BURI HOLDING COMPANY LIMITED
  • Address: No. 591, Sukhumvit Road, Khlong Tan Nuea Sub-district, Vadhana District, Bangkok
  • Tel: 0-2261-0261
  • Website: https://www.bhirajburi.co.th
  This Privacy Policy is reviewed and comes into effect on 25 May 2022.