Orbix Trade Co., Ltd. (“Company”) has adhered to operating its business with morality and respect for your personal rights. Therefore, the Company emphasizes the significance of personal data protection and personal data security to ensure that your personal data received by the Company will be used according to the objectives and under the laws. The Company has arranged this Privacy Notice for Business Counterparties and Business Associated Persons (“Privacy Notice” or “Notice”) to notify the Company’s business counterparties and business associated persons to acknowledge the objectives and details for collecting, gathering, using and/or disclosing personal data as well as other rights of you according to the laws.
1. A person who would be applied by this Privacy Notice
This Privacy Notice has been arranged to notify you, as the Company’s Business Counterparties or Business Associated Persons, to acknowledge the objectives and details regarding the data processing of your personal data as well as other rights according to the laws on personal data protection whereby “Counterparties” and “Business Associated Person” mean:
(1) “Business Counterparties” means an individual who sells or offers to sell goods and/or provides or offers to provide services to the Company and includes any individual who is an agent or authorized representative(s) of any juristic persons that is a business counterparty of the Company, and any individual whose personal data has been collected by the Company for the purpose of contacting or entering into a transaction between the Company and such person or the company of which such person is an employee, officer, agent or authorized representative.
(2) “Business Associated Persons” means any persons other than a customer or Business Counterparties of the Company but refers to a business partner, an individual who is involved in the Company's business operation, such as a business partner, an official of a governmental agency that regulates business operation or supervises a compliance with the law, and also includes an individual who is an agent or authorized representatives of a juristic person that is a business partner of the Company.
2. Channels for collecting personal data
The Company generally collects personal data from you directly. In some cases, however, the Company may collect your data from other sources, such as the DBD data warehouse, to identify and select the service providers.
3. Personal data that the Company collects, uses, and/or discloses
The Company may collect, use, and/or disclose the following personal data:
| Types of Data | Example of Data collected, used, and/or disclosed by the Company |
|---|---|
| Data used for identification and personal data | - Name-surname - Signature - Information presented on the documents issued by governmental agencies, i.e., a copy of identification card, a copy of passport, a copy of identification card of the officials/state enterprise employees, or a copy of house registration. Remark: Normally, the Company has no objective in collecting and using sensitive data, such as religion and blood type, as presented on a copy of the documents issued by governmental agencies. To keep your personal data private, the Company recommends you redact the said personal data before sending or disclosing it to the Company; otherwise, the Company may do so for your benefit. |
| Contact details | - Residential address and address of workplace - Telephone number, mobile phone number, email |
| Data on employment | - Occupation, position, company that works for |
| Data on finance and contracts | - Bank account number - Contracts or agreements executed with the Company |
| Other Data | - Data related to ability or suitability evaluation in rendering service - Data on sanction lists - Request to exercise rights according to the laws |
(1) Objectives and the lawful basis for collecting, using, and disclosing personal data
The Company will collect, use, and/or disclose personal data only when there is a lawful basis that allows the Company to collect, use, and/or disclose personal data for performing obligations under the contract that you are a party thereto, for abiding by the laws, for a legitimate interest, for processing according to your request, and/or for performing under other reasons of the lawful basis for the purpose of collecting, using, and/or disclosing personal data according to this Privacy Notice, which will be as follows:
In this regard, the following objectives may apply differently between the Company’s Business Counterparties and the Business Associated Persons of the Company or may apply to some groups or some persons of the Business Counterparties and the Business Associated Persons. Therefore, please consider the characteristics of objectives according to the relationship between you and the Company on a case-by-case basis.
| Data Processing Objectives | Personal Data to be Collected, Used, and/or Disclosed | Lawful Basis |
|---|---|---|
| Liaison and Communication | The Company will collect and use the data used for person identification, work position, and contact details, such as name-surname, and contact data, i.e., email and phone number, for liaison and communication. | For performing a contractual obligation and/or for the Company’s legitimate interest. |
| For consideration of qualifications of the sellers or the service providers | If you are a Business Counterparty, during the process of evaluating the qualifications of the Business Counterparties, the Company will collect and use your name and surname to check your name against the sanction list of the Anti-Money Laundering Office. The Company will also use information about the evaluation of your ability or suitability in rendering services for selecting the service providers. | For the Company’s legitimate interest. |
| For performing the process before entering into the contracts, for entering into the contracts, and for performing obligations under the contracts | The Company will collect and use the data used for person identification, work position, and contact details, such as name-surname, a copy of identification card or passport, signature, company that works for, email, phone number, and data on the bank account for entering into the contracts and performing obligations thereunder. | For performing obligations under the contracts. |
| For consideration of contract renewal with the service providers | The Company will collect and use data about name-surname and evaluation of ability or suitability in rendering services to consider a contract renewal with the service providers. | For the Company’s legitimate interest. |
| For compliance and internal audit on complaints and protection of frauds for transparency | The Company will collect and use the data about name-surname, data on finance and contracts, and data about the evaluation of ability or suitability in rendering services for benefits on the internal audit to protect against fraud for transparency. | For the Company’s legitimate interest |
To comply with the personal data processing objectives mentioned above, the Company may be required to transfer/disclose your personal data to external organizations that are the data processors of personal data, e.g., the service providers who act as legal advisors to review and arrange the related contracts, and service providers on procurement.
5. Will the Company send your data to foreign countries?
The Company may be required to send or transfer your personal data to other data receivers, which would be considered a part of the Company's regular business operation. In this connection, the Company will monitor to ensure that such delivery or transfer of personal data is in accordance with the laws and will procure a protective measure for personal data, as deemed required and appropriate, in line with a confidential protection standard, such as to arrange an agreement with a foreign data receiver to confirm that your personal data will be protected under a personal data protective standard equivalent to those provided in Thailand.
6. How long does the Company keep your data?
The Company will keep your personal data throughout a period in which you are a customer or have a relationship with the Company or a period as required for achieving related objectives as provided in this Privacy Notice. And, when you end a relationship with the Company, the Company will continually keep your personal data after that for a period of prescription or other appropriate period of time according to the data processing objectives under this Privacy Notice.
In this regard, the Company will process proper procedures to delete or destroy personal data or to redact those data so that they are unable to identify your identity when there is no necessity or end of those specified periods.
7. How does the Company protect your personal data?
The Company will well keep your personal data in accordance with the Technical Safeguards, Administrative Safeguards, and Physical Safeguards, to maintain its confidentiality, accuracy, and readiness of use to prevent unauthorized or illegal access, collection, adjustment, amendment, use, and/or disclosure of personal data, by the applicable laws.
The Company has arranged an appropriate measure to prevent a personal data breach, whereby the Company has determined policies, rules, and criteria for protecting personal data, such as a measure for personal data accessing control and use of secure and proper equipment to keep and process personal data, personal data accessing restriction, determination on personal data accessing rights of users, rights to grant the assigned staffs to access the data, and duties and responsibilities of users, for preventing access to personal data, disclosure, cognition, or unauthorized copying personal data, or stealing equipment to keep and process personal data. The Company procures a measure for tracking the history of access, adjustment, deletion, or transfer of personal data that is in line with and suitable for the method and equipment for keeping, using, or disclosing personal data, including an inspection for evaluating the effectiveness of implementing such policies, rules, and criteria for protecting personal data.
8. Your rights regarding personal data
The Company acknowledges and respects your legal rights, whereby you can exercise the rights according to the conditions provided by laws as follows:
You can contact the Company to exercise any rights mentioned according to the Company’s contact details, which are given through an application, website: www.orbixtrade.com, or the Company’s email at [email protected].
9. Will the Company amend or adjust this Privacy Notice?
The Company may review, amend, add, adjust, or change the content of this Privacy Notice from time to time so that you can acknowledge an updated collection, use, and disclosure of personal data. If there are any amendments, additions, adjustments, or changes to this Privacy Notice, the Company will notify you for acknowledgment through the Company’s website.
10. Notification of Objectives and Details for Personal Data Processing
In the case where notification of new objectives or details as provided in this Privacy Notice is unable to do or would be an obstacle to a use or disclosure of your personal data which the Company has received indirectly from other sources, particularly for achieving a purpose of scientific, historical, statistic research, the Company shall procure an appropriate and standardized measure to protect rights, freedom, and benefits of the data subject as provided in this Privacy Notice.
If you give personal data of other persons (i.e., family members or other contact persons) to the Company (i.e., name, surname, date of birth, age, address, relationship, signature, and contact detail) for an objective specified in this Privacy Notice. In that case, you should proceed with an action to ensure that those people have been informed of personal data disclosure to the Company. You should notify those persons of this Privacy Notice and/or ask for consent from those persons (if required) and/or based on other lawful criteria or basis.
11. Channels for Contacting with the Company and the Data Protection Officer
Should you have any suggestions or inquiries about the details of the collection, use, and/or disclosure of your personal data, you can contact the Company at:
Approved by the Senior Director and announced as of June 19, 2024.