Privacy Notice

Euro Creations has published this Privacy Notice to clarify the details and methods on how Euro Creations (“we”) handle information that we receive from you, the purposes for the collection, use, disclosure, and processing, including the retention period of such Personal Data, and your rights as the data subject.

We conduct business in Thailand, the processing of your Personal Data shall therefore fall under the compliance of and is required to comply with Thailand’s Personal Data Protection Laws accordingly and will process and keep protecting your Personal Data in accordance with the details as described in this Privacy Notice. 

1. What Personal Data we collect & methods to collect/receive your Personal Data

1.1 Euro Creations Group collects and receives your Personal Data via the following methods:

1. Personal Data which you directly provide to Euro Creations : You may directly provide your Personal Data to Euro Creations. This case usually occurs when you contact Euro Creations to make enquiries, complete forms either by online or by document, apply for services or join activities, request for information, receive marketing communications, or provide comments or feedback to Euro Creations, etc.
2. Personal Data which Euro Creations automatically collect from you : Euro Creations Group may automatically collect some technical information, in relation to your devices, activities and visiting patterns and browsing history, by using Cookies and other similar technologies. For more details, please see Cookies Policy
3. Personal Data which Euro Creations receives from third parties : Euro Creations may, from time to time, receive your Personal Data from third parties, such as vendors, supplier and contracting parties and professionals, personnel of Euro Creations and candidates.

1.2 In collecting your Personal Data, you will be informed of details set out in this Privacy Notice, including but not limited to, the lawful basis for the collection, use, disclosure and/or processing of Personal Data in accordance with the lawful purposes, or in the event that the Personal Data Protection Laws require your consent to be provided, Euro Creations will request for your explicit consent in order to process your Personal Data. 

1.3 Personal Data which Euro Creations collects and processes under this Privacy Notice is the Personal Data of the following categories of data subject:

1. Customers and Investors,  i.e., natural persons who are website visitors, service recipients, seminar participants, and other persons who contact Euro Creations to request information or services from Euro Creations, regardless of whether such Personal Data was directly or indirectly received.
2. Contracting Parties, Professionals and other persons relating to the business of Euro Creations, i.e., natural persons who are contracting parties or contractually related with Euro Creations, including business partners, sellers, suppliers, service providers, contractors, advisers, investment professionals, and other similar persons.
3. Personnel of Euro Creations, i.e., natural persons who are staff, employees or persons who work for Euro Creations, directors, managers, executives, professionals, and persons who directly receive monthly salaries, wages, benefits, or any other types of compensation from Euro Creations, including the family members of such personnel of Euro Creations.
4. Candidates, i.e., natural persons who submit an application or details relating to their profile to Euro Creations, either in the form of written or verbal, with the purpose to apply for the job, as staff or employees or interns of Euro Creations who are not yet chosen by Euro Creations, including the family members of such candidates and references.

1.4 Your Personal Data which is collected and processed under this Privacy Notice, regardless of whether such Personal Data was directly provided by you to Euro Creations or automatically collected from you by Euro Creations, or was provided to Euro Creations by third parties, such as 

1. Personal Data, such as first name, last name, date/month/year of birth, age, gender, identification number and copy of passport or ID card, signature, nationality, marital status, and family members information.
2. Contact details, such as address, telephone number, e-mail, social media contact details, and details of emergency contacts.
3. Sensitive Personal Data, such as religion, criminal record, health data, health examination result, disability, and biometric data.
4. Financial information, such as bank account number, billing information such as billing address and credit card information; and information regarding various types of tax.
5. Technical information, such as the information of access to Euro Creations’ websites and systems, computer traffic data (Log), contact and communication information between you and other users, information from using records e.g., computer IP address, device identification number, mobile phone network information, connecting information, browser category, system access record, information of referring website, use of system record, login or transaction information, customer behavior information, system access statistics, access time, your searching information, the use of functions in systems, and information that Euro Creations collects through the use of Cookies or other similar technologies.
6. Training, and Work Experience information, such as training background, certificate or transcript, result or raking of points, level of education, language skills, professional licenses information, registration number, registration starting date, registration expiration date, registration renewal information, duty performance information, work starting date, information of training and test provided by Euro Creations or other relevant organizations, diploma, certificate, work experiences, monthly salaries or wages.
7. Other information, such as photograph and/or voice recording by CCTV, photograph, footage, video, voice recording of conversations and tendency information of goods or services purchasing

1.5 In the event that Euro Creations collected your Personal Data before 1 June 2022, Euro Creations will continue processing such Personal Data in accordance with the Personal Data Protection Laws.  

2. Purposes and legal basis for collection, use and disclosure of Personal Data

2.1 Euro Creations process your Personal Data for the following purposes (collectively referred to as “Specified Purposes”) and under the following legal basis: 

• necessary for the performance of a contract which you have entered into as a party with the Euro Creations or for complying with your request prior to entering into such contract;
• for compliance with the law by Euro Creations;
• necessary for the legitimate interest of Euro Creations, or other persons or juristic persons other than Euro Creations;
• necessary for the performance of a task carried out in the public interest by Euro Creations, or for exercising of official authority vested in Euro Creations;
• for preventing or suppressing danger to life, body or health of a person;
• for the achievement of purposes relating to research or statistics, for which suitable safeguard measures to protect your rights and freedom have been implemented;
• consent which you have given to Euro Creations, where exceptions or legal basis specified above cannot be relied on, or according to the cases specified in the table below. In the case that Euro Creations has specifically requested consent from you for any Personal Data, Euro Creations will process such Personal Data pursuant to the purpose which you have been informed of and consented to, and Euro Creations will only process any Personal Data which constitutes sensitive Personal Data in the case that Euro Creations is able to do so under the laws or has obtained explicit consent from you.

Purposes	Legal basis for processing
(a) To comply with the duties under the relevant laws or regulations to which Euro Creations is subject. In order to comply with the relevant laws, regulations and rules, as well as to perform the duties as set out in laws and regulations relevant or applicable to Euro Creations, including but not limited to laws on securities and exchange, laws on derivatives, laws on taxation, laws on labor protection, laws on computer crime and Personal Data Protection Laws, of which both enforceable as of the present and to be amended or added in the future.	The use of your Personal Data is necessary to the performance of duties of Euro Creations in accordance with laws relevant applicable to Euro Creations, including complying with court orders.
(b) To contact and communicate, marketing communications, perform data analytics and improve the services of Euro Creations in order to respond to your service requests, inquiries, or suggestions, and to ensure that Euro Creations can efficiently provide such services to you and other persons  – To contact you via telephone call, short messages service (SMS), e-mail, mail or via any other contact channels in order to ask, inform, verify or confirm information relating to your account, conduct survey or keep you updated on any news related to services provided by Euro Creations; – To manage your relationship with Euro Creations and provide various services to you; – To keep you updated on any news related to the organization products and services provided by Euro Creations, including providing marketing communication messages to you (or the organization you represent); – To efficiently improve and facilitate the provision of services to you; – To achieve any benefits related to the operation of Euro Creations, such as for customer behavior, statistics, service improvement and marketing communication or advertisement including the provision of content, advertisement, activity announcement and any special offer, as well as providing appropriate recommendations on services that may be of interest to you; – To maintain records of photographs, footages, video and voice recording of conversations during the provision of services of Euro Creations.	The use of your Personal Data is necessary for:  – the legitimate interest of Euro Creations Group or other persons or juristic persons; – the achievement of purposes relating to research or statistic;  The Euro Creations Group will send you marketing communication messages only when you subscribe to receive marketing communication or when you consent to receive marketing communication.
(c) To manage human resource in order to enable Euro Creations to determine the most appropriate decision about recruitment and human resource management  – To consider the qualification of applicants, selection of staff, employees, interns, and/or scholarship recipients (as the case may be) and to carry out any activity that may be beneficial to you including advertising, maintaining records of photograph, footages, video and audio from a conversation, publicizing news regarding recruitment, internship application, and scholarship application, as well as improving the recruitment process and workforce of Euro Creations; – To manage the payment of a monthly salaries, remunerations or benefits specified in the employment contract in which you are a party to;- – To comply with employment contract in which you are a party to, as well as to comply with the laws, such as collecting and maintaining records of information relating to accounting, taxation, withholding tax, labor protection, management of occupational safety, health, and environment, and managing your social security funds and provident funds; – To carry out a training session, providing equipment, facilities and welfare such as health insurance, medical expenses and employer loans; – To maintain records of illness in order to use such information for welfare management, and to verify the compliance of the human resource management regulations of the Euro Creations.	The use of your Personal Data is necessary for:  – the performance of contracts in which you are a party with the Euro Creations or to proceed with your request before entering into such contract; – the compliance of the duties of Euro Creations in accordance with laws relevant and applicable to Euro Creations, including complying with court orders; or – the legitimate interest of Euro Creations or other persons or juristic persons.
(d) To conduct procurement and to retain a positive professional relationship between Euro Creations and you (or the organization you represent)  – To verify information, qualification, and proceed with the procurement process of the Euro Creations and maintain records of photographs, footages, video and audio from conversations; – To perform any contractual obligation with you (or the organization you represent) in order to purchase goods or services from you (or the organization you represent), including contacting you to manage the contract between Euro Creations and you (or the organization you represent) in order to receive goods or services, proceed with warranty claims, and make or claim a payment on goods, services, or any expenses to you (or the organization you represent) (if any);- – To manage a relationship between Euro Creations and you (or the organization you represent); – To comply with the laws such as collecting and maintaining records of information relating to accounting, taxation and withholding tax.	The use of your Personal Data is necessary for: – the performance of contracts in which you (or the organization you represent) are a party with the Euro Creations or to proceed with your (or the organization you represent) request before entering into such contract; – the compliance of duties of Euro Creations in accordance with laws relevant and applicable to Euro Creations, including complying with court orders; or -the legitimate interest of Euro Creations or other persons or juristic persons.
(e) To implement security measures – To verify your information on use of services for security development in relation to the use of services, management and protection of technology infrastructure, such as the provision of WiFi services in which Euro Creations may use your Personal Data to the extent necessary, and may put in place encryption before using and/or arranging for random check, as well as conducting accessibility testing by others for the purpose of risk management, detection, prevention or removal of fraud or other activities that has a tendency to violate the relevant laws, regulations, procedures or terms and conditions of Euro Creations; – To control access to the building, and to ensure security of Euro Creations’ personnel and visitors, as well as the property and other information located or stored at the buildings and premises of Euro Creations, to observe and monitor building entrance, secure location, protected rooms, technology infrastructure or operational information and other premises (collectively referred to as “buildings and premises”) for the prevention of an unauthorized entry of buildings and premises of Euro Creations, and to prevent, detect, and investigate on any security related incident such as unauthorized entry of buildings and premises of Euro Creations, robbery, fire incident or physical assault; – To record and maintain records of photos, images and/or audio via closed circuit television (CCTV), photographs, footages, video and voice recording from conversations.	The use of your Personal Data is necessary for the legitimate interest of Euro Creations or other persons or juristic persons.
(f) To carry out other purposes that Euro Creations have notified you at the time of collection of Personal Data  Euro Creations will notify you of any other purposes that Euro Creations needs to use your Personal Data apart from the specified purposes mentioned above, or when Euro Creations wishes to modify its former Specified Purposes or when it is necessary for Euro Creations to specifically obtain your consent for the processing of your Personal Data, by contacting you via the contact details given to Euro Creations.

2.2 As the Personal Data which Euro Creations will process for the Specified Purposes as stated in Clause 2.1 above relates to the compliance with the laws or contracts or is necessary for entering into a contract with you, whereby, such Personal Data is necessary for the achievement of such Specified Purposes, if you do not provide such Personal Data to Euro Creations , there may be a legal impact or Euro Creations may not be able to perform its legal obligation under the contract entered into with you or may not be able to enter into a contract with you (as the case may be). In such case, Euro Creations may be required to decline to enter into a contract with you or terminate the relevant services to you, partly or entirely. 

2.3 In the case that Euro Creations intends to use your Personal Data for a purpose not specified above, Euro Creations will provide an additional privacy notice to explain the use of Personal Data for such purpose. You should read such additional privacy notice along with this Privacy Notice. 

3. Disclosure of Personal Data

3.1 Euro Creations may disclose your Personal Data under the Specified Purposes and in accordance with the laws and regulations to the following entities and persons: 

1. Euro Creations, including their staff, employees, directors, managers or personnel of Euro Creations as deemed relevant and necessary (on a need-to-know basis), for the processing of your Personal Data;
2. The organizations requesting for the disclosure of information by virtue of the laws, such as requesting information for the prosecution or legal prosecution, or relating to the legal proceedings, for example, Anti-Money Laundering Office, the National Anti-Corruption Commission, Royal Thai Police, Department of Special Investigation, Office of the Attorney General, and the courts;
3. Alliances, business partners, service providers, service recipients and Data Processors assigned by Euro Creations to be responsible of providing services or managing of Personal Data, such as improving or maintaining the security standard of the systems and the technology system, payment systems, audit, human resource management or other services which may be beneficial to you.

3.2 The disclosure of your Personal Data to third parties shall be in accordance with the Specified Purposes or other purposes permitted by laws, provided that if the law requires your consent, Euro Creations will request for your explicit consent in advance.

3.3 In the event that Euro Creations discloses your Personal Data to third parties, Euro Creations will put in place appropriate safeguards to protect the Personal Data that has been disclosed and to comply with the standards and duties relating to the protection of Personal Data as prescribed by the Personal Data Protection Laws.

3.4 In the event that Euro Creations sends or transfers your Personal Data outside Thailand, Euro Creations will ensure that the recipient country, the international organization or such overseas recipient has a sufficient standard for the protection of Personal Data. In some cases, Euro Creations may request your consent for the transfer of your Personal Data outside Thailand, subject to the requirements under the Personal Data Protection Laws. 

4. Retention Period

4.1 Euro Creations will retain your Personal Data for the period necessary to fulfil the Specified Purposes for which the Personal Data was processed, whereby the retention period may be changed depending on the Specified Purposes for which such Personal Data was collected and processed.

4.2 Euro Creations will also retain Personal Data for the period prescribed under the applicable laws, having regard to the business practices in relation to each category of Personal Data. After the aforementioned retention period, Euro Creations will delete such Personal Data from the storage or systems of Euro Creations without prior notice to you.

5. Rights of Data Subject

As the data subject, you have the following rights in relation to your Personal Data, subject to the rules, methods and conditions under the Personal Data Protection Laws. In this regard, if you wish to make a request to exercise your rights, you can contact Euro Creations by using the contact details in our website.

5.1 Right to Access
You have the right to access your Personal Data and may request Euro Creations to provide you with a copy of such Personal Data in accordance with the requirements under the Personal Data Protection Laws, including to disclose how the Euro Creations receive your Personal Data, which is collected, used and disclosed by the Euro Creations without requiring of your consent, to the extent permitted by the Personal Data Protection Laws.

5.2 Right to Data Portability
You have the right to obtain your Personal Data in the format which is readable or commonly used by ways of automatic tools or equipment, including to request to send or transfer your Personal Data to another Data Controller or to you, unless it is technically unfeasible to do so. Your rights to data portability shall be in accordance with the requirements under the Personal Data Protection Laws.

5.3 Right to Object
You have the right to raise an objection to the processing of your Personal Data, and Euro Creations will conduct so in case that the Euro Creations; 

1. processes your Personal Data based on our or third parties’ legitimate interest or public interest, except in the event that the Euro Creations an demonstrate compelling legitimate grounds, or the processing of your Personal Data is carried out for establishment, compliance with or exercise of the legal claims or defense of the legal claims;
2. processes your Personal Data for the purpose of direct marketing; or
3. processes your Personal Data for the purpose of scientific, historic or statistic research, unless it is necessary for conducting activities for the public interest of Euro Creations.

In the event that you object to the processing of Personal Data, please kindly inform us whether you wish to delete your Personal Data or to restrain Euro Creations from processing such Personal Data. 

5.4 Right to Erasure
You may request Euro Creations to delete, destroy or anonymize your Personal Data in certain circumstances as follows: 

1. There is no further necessity to retain your Personal Data according to the Specified Purpose for processing your Personal Data;
2. You withdraw your consent which is the basis of collecting and processing the Personal Data, and Euro Creations has no legal ground for collecting or processing such Personal Data;
3. You object to the processing as mentioned in Clause 5.3; or
4. The collecting or processing of your Personal Data is unlawful.

The abovementioned cases shall not apply to the processing that is necessary for the purpose of freedom of expression, preparing of the historic or statistic documents, performing a task carried out in the public interest, complying with the law for achieving purposes with respect to preventive medicine or occupational medicine or public interest in public health, establishment, compliance with or exercise of the legal claims or defense of the legal claims or compliance with the law.

5.5 Right to Restriction
You have the right to request a restriction to the processing of your Personal Data in certain circumstances as follows: 

1. Euro Creations is pending the verification of the accuracy of Personal Data as per your request;
2. In case of Personal Data which shall be deleted or erased according to Clause 5.4 that you request a restriction to the use instead;
3. Euro Creations has no further necessary to use your Personal Data, however, you have a necessity and therefore request Euro Creations to retain such Personal Data, for establishment, compliance, or exercise of the legal claims, or for defense of the legal claims; or
4. Euro Creations is pending the verification according to Clause 5.3 (a) or Clause 5.3 (c) in order to reject your objection request pursuant to Clause 5. 

5.6 Right to Rectification
You have the right to request that your Personal Data be rectified if the Personal Data is inaccurate, not up-to-date or incomplete, or may cause a misunderstanding. 

5.7 Right to Withdraw Consent
In the event that Euro Creations relies on your consent as the legal basis for processing your Personal Data, you have the right to withdraw such consent which has been provided to the Euro Creations at any time that such Personal Data is in the possession of the Euro Creations. 

5.8 Right to Lodge a Complaint
If you have any concerns or questions about any aspect of Euro Creations’ practices in relation to the processing of your Personal Data, please contact Euro Creations using the contact details set out in Clause 8 (How to contact Euro Creations) of this Privacy Notice. In case of an alleged infringement of Personal Data Protection Laws, you have the right to lodge a complaint to the Office of Personal Data Protection Committee. 

Euro Creations will apply our best effort of the capability of the relevant systems to facilitate and carried out at your request without delay, unless it appears that to carry out at such request causes undue burden on or would involve excessive or disproportionate effort of Euro Creations or is in the risk of violating of the protection of others’ Personal Data or illegal or impossible to perform such request. 

6. Security for the Retention of Personal Data

Euro Creations have in place and/or adopt the Personal Data storage systems, which has appropriate mechanism and technique and security standard according to the Personal Data Protection Laws and the relevant regulations, including the limitation of access of your Personal Data by staff, employees and representatives of Euro Creations for the purpose of preventing your Personal Data from the unauthorized usage, disclosure, erasure or access. 

7. Link to websites, products and services of third parties

Provision of services of Euro Creations may link to websites, applications, products and services of third parties, which such third parties may collect certain information in relation to the use of such service. This Privacy Notice is solely applied to the processing of Personal Data under the purpose specified by Euro Creations. Euro Creations could not be responsible for the security or privacy or any of your information collected by websites, applications, products and services of such third parties, even you click the link appeared on the service of Euro Creations. In this regard, you should be careful and verify the privacy notice or privacy policy of websites, applications, products and services of such third parties. 

8. How to contact Euro Creations

If you have any questions in relation to this Privacy Notice, or would like to exercise your rights as set out in this Privacy Notice, you could contact Euro Creations through the Data Protection Officer of Euro Creations by using the following details; 

Euro Creations Public Company Limited

Contact address: 1050 Sukhumvit Alley, Phra Khanong Tai, Khet Phra Khanong, Bangkok 10260

Telephone number: +662-744-9624  |  Email: info@eurocreations.co.th

9. Applicable Law

This Privacy Notice shall be governed by and construed in accordance with Thai laws, and Thai courts shall have jurisdiction over any dispute that may arise out of or relate to this Privacy Notice. 

10. Changes to this Privacy Notice

Euro Creations may make changes to this Privacy Notice from time to time, in order to reflect any changes to our processing of your Personal Data, and to comply with changes to the Personal Data Protection Laws or any applicable laws. In this regard, Euro Creations will notify you of any significant changes to the Privacy Notice through appropriate means. Nevertheless, Euro Creations encourages you to review the Privacy Notice for any changes from time to time.

This Privacy Notice shall be effective from 1^st June 2022