Privacy Policy

Introduction

1. When the European Union has issued a new regulation on the protection of Personal Data, known as "GDPR" (EU General Data Protection Regulation), which is an update to the existing law (EU Data Protection Directive 95/46/EC) which has been in force for more than 20 years, causing significant changes in the principles of Personal Data protection.
2. The GDPR came into force on May 25, 2018, which, in addition to being effective for data transmission within EU member states, for Thai entrepreneurs, if they are going to communicate with people of member countries, there must also be suitable and sufficient Personal Data protection measures. As a result, Thai entrepreneurs have to adapt to support such Personal Data protection standards.
3. As for Thailand, for more than 20 years, the government has successfully pushed for the Personal Data protection law and announced it in the Royal Gazette on May 28, 2019 and shall come into force on June 1, 2022 (significantly influenced by GDPR).
4. Häfele (Thailand) Limited (hereinafter referred to as "Häfele”) is aware of preparations to support the efficient handling of Personal Data in Häfele's possession. Therefore, this Privacy Policy has been created to be in line with the GDPR and the Personal Data Protection Act B.E. 2562 ("PDPA").
5. This Privacy Policy explains how Häfele collects, uses, stores, discloses and/or transfers Personal Data of employees, and current and future customers with the purpose of protecting the privacy of their Personal Data.
6. Häfele is committed to ensuring that your privacy is protected and the processing of your Personal Data shall be in accordance with applicable laws and regulations (this may be amended from time to time and replaced by new laws.). Häfele shall only collect, use, store, disclose and transfer your Personal Data in accordance with this Privacy Policy.
7. This Privacy Policy applies to all online or offline communication channels, which Häfele collects your Personal Data whether received directly from you, through the exhibition, in Häfele showrooms, events, by phone, through the call center, through email or social media platforms (such as web pages, Facebook or Line) and other channels relating to the provision of products and services to you, including, Häfele website https://www.hafelethailand.com/ and https://www.hafelehome.co.th/ and or other websites ("Website") (hereinafter collectively referred to as "communication channels").
8. 8. This Privacy Policy was last updated on May 1, 2022. Häfele reserves the right with sole discretion to modify, amend, delete and update this Privacy Policy from time to time. Häfele shall use reasonable efforts to notify you of any modifications to the provisions of this Privacy Policy.
9. 9. Please read this Privacy Policy carefully and strictly implement it. For Häfele employees, your compliance with this Privacy Policy is important and, if violated, could have serious consequences for Häfele's compliance with data protection laws and regulations. If you have any questions or requests Please contact Häfele's Legal Department, its representative or Häfele's Data Protection Officer.

Definitions

Personal Data
Any data relating to a Person, which enables the identification of such Person, whether directly or indirectly, but not including the data of the deceased Persons in particular.

Data Controller
A Person or a juristic person having the power and duties to make decisions regarding the collection, use, or disclosure of the Personal Data.

Data Processor
A Person or a juristic person who operates in relation to the collection, use, or disclosure of the Personal Data pursuant to the orders given by or on behalf of a Data Controller, whereby such Person or juristic person is not the Data Controller.

Committee
The Personal Data Protection Committee.

Biometric Data
Personal Data arising from the use of techniques or technologies involving the use of an individual's physical or behavioural features to enable identification of that individual as unique as other persons, such as facial image data, iris simulated or fingerprint simulated data.

Sensitive Personal Data Personal Data that is completely personal to an individual but is sensitive and vulnerable to unfair discrimination. It is therefore necessary to proceed with extreme caution.

Data Subject
A person to whom the data is directed, not owned in the form of property rights or as a person who created that data.

Processing
Any action or set of actions which acts on Personal Data or a set of Personal Data whether by automated methods or not, such as collecting, recording, organizing, structuring, retaining, changing or modifying, accepting, considering, using, disclosing by transmission, publishing or any other action which results in availability, placement or combination, restriction, deletion or destruction (GDPR Article 4(2)).

Consent
Any indication given specifically, expressly, unquestionably according to the wishes of the Data Subject, by command or by explicit action or confirmation of an agreement on the processing of Personal Data of the Data Subject.

Data Protection Officer or "DPO"
An independent person with Personal Data protection expertise and a duty to report to management level. The Data Protection Officer assists Data Controllers with advice on monitoring compliance with laws within Häfele, informing and advising Häfele of its Personal Data protection obligations, providing advice on Personal Data Protection Impact Assessments (DPIAs).

Collection of Personal Data

Häfele may collect your Personal Data, including:

- Personal Data that identify you, such as title, name, surname, nickname, gender, age, date of birth, occupation, job title, details and/or a copy of your national ID card, passport, copy of house registration and copies of government-issued cards, blood types, photographs, signatures and any other data you share with Häfele which may be considered Personal Data.

- Contact data such as phone numbers, mobile phone number, fax number, address, zip code, email, company email, business phone number, and business address (which includes city, zip code and country).

- Financial data such as salary, salary range, salary slip, salary certificate, the financial institution and details of your loan applications.

- Vehicle data such as vehicle registration number and vehicle model.

- Data about the service, such as data about the use of the service, service contact history (between you and Häfele), customer satisfaction, and data related to claims, other data such as opinions, questions, inquiries, complaints, survey responses, preferences, interests, or hobbies.

- Sensitive Personal Data such as religion on identity cards, race on identity, verification documents, and biometrics (e.g. fingerprint simulation data) face and iris simulation data).

- Data that Häfele collects about you for the provision of services and product sourcing, Häfele may collect the following data from your use of Häfele websites or applications through Häfele communication channels or from other sources automatically which may include personally identifiable data such as still images, animations, images and/or sounds, interests such as products you have selected, upcoming projects, and reasons for choosing a particular supplier, behavioural data, such as data about your use of the application (which includes the date and time of use, page response time, download error, and data about the advertisements you have viewed and other data collected by Häfele) or claim data relating to communication channels, products and services, technical data such as computer identification numbers (IP address) used to connect your mobile device to the Internet, login data, operation data, operating platform type, and version time zone setting; cookies, which include data about Internet use by users of an organization's computer (e.g. what websites each user visits, what documents to download, security incident, protection measures by gateways, etc.); activity data related to content distribution, targeting or use of protected documents on the website, such as changing permissions and document data about the person performing such activities, and cookies when you visit a website or an application Cookies are used to collect technical information about the services you use and how you use such services

- Häfele may collect Personal Data about your family members or other persons such as emergency contacts, references, representatives/representatives, beneficiary, including name and telephone/mobile phone number of such person and any other information relating to any person that you have provided to Häfele in any form. In providing information of third parties to Häfele, you represent and warrant that you have the authority to do so and allow Häfele to use such Personal Data in accordance with this Privacy Policy. You are also obligated to notify them of this Privacy Policy and/or obtain their consent that if necessary.

However, Häfele shall collect Personal Data for purposes, scope and using lawful and fair means. The collection will only be done to the extent necessary for the purposes of Häfele's operations. Häfele shall proceed to inform the Data Subject to give consent electronically or according to Häfele's methods. In the event that Häfele collects Sensitive Personal Data of the Data Subject, Häfele shall obtain explicit consent from Data Subjects prior to collection unless the collection of Personal Data and Sensitive Personal Data is subject to exceptions as stipulated by the Personal Data Protection Act B.E. 2562 or other laws.

Source of Personal Data

Häfele may obtain your Personal Data in two ways:

1. Obtaining your Personal Data directly from you - this may be Personal Data that you have provided directly to Häfele or through Hafele or existing with Häfele, both arising from the use of products and/or services, contact, visit, search through digital channels, branches, websites, call centre, authorized person or any other channel.
2. Obtaining your Personal Data from sources other than directly from you, such as government agencies, financial institution, business partner, credit data company and data service providers, etc. Häfele shall collect data from other sources only with your consent as required by law unless Häfele is necessary as permitted by law.

Purpose of data processing

Häfele shall collect or use your Personal Data for the benefit of Häfele's operations, such as contracts, financial transactions, company activities, various coordination or to improve the quality of work to be more efficient, such as creating a database, analyze and develop Häfele's operational processes, and for any other purposes that are not prohibited by law and/or to comply with laws or regulations related to Häfele's operations. Häfele shall store and use such data only for the period necessary for the purpose that has been notified to you or as required by law. For the purpose that not specified above, you shall be notified when Häfele requests the collection of Personal Data. Häfele shall collect, use or disclose your Personal Data for the aforementioned purposes only if the following conditions are met:

1. You have given your legal consent to Häfele.
2. It is necessary for the performance of the contract to which you are a party or to be used to process your request before entering into that contract.
3. It is the prevention or suppression of danger to life, body or health of a person.
4. It is necessary for the performance of duties in carrying out missions for the public interest of Häfele or performing duties in exercising the authority assigned by the state to Häfele
5. It is necessary for the legitimate interests of Häfele or of another person or entity unless such benefits are less important than your fundamental rights in your Personal Data.
6. It is necessary to comply with the law.
7. There are historical documents or archives for public use or relating to research studies or statistics, Häfele shall provide appropriate safeguards to protect your rights and freedoms.

Häfele shall not act differently from the purpose of data collection unless:

1. Notify you of new objectives and obtain consent from the Data Subject.
2. To be comply with the Personal Data Act or other relevant laws.

Disclosure and Transfer of Personal Data

Disclosure of Personal Data

Häfele may share your Personal Data within the Häfele network for the purposes described above. Häfele shall take such steps to ensure that access to Personal Data is limited to its employees and representatives only on a need-to-know basis.

In addition, Häfele may share your Personal Data outside of Häfele's network with the following persons: for the purposes stated in this Privacy Policy.

(a) Within the group: parent company, subsidiaries and affiliates - Häfele may need to transfer your Personal Data or allow access to that Personal Data to other companies within the Group for the purposes described in this Privacy Policy which shall make other companies within the Group can rely on the consent that Häfele has received from you;

(b) Business partners: to conduct business and services related to Häfele's business - In any case, Häfele may disclose to and receive your Personal Data from business partners, including Häfele partners who sell Häfele products or services to you or who offer products or services in conjunction with Häfele or the products or services of these partners may be offered to you;

(c) Authorized Distributors and Sales Agents: From time to time, Häfele may disclose and receive Personal Data from authorized vendors that you have chosen or are close to you to provide you with services.

(d) Service providers / suppliers of products/services / subcontractors: Häfele may use the services of other companies, agents or contractors to provide services on Häfele's behalf or to assist in the provision of products and services to you. Häfele may share your Personal Data with service providers or third party suppliers of Häfele products/services, including but not limited to, (1) data technology system service providers and data technology companies (2) analytics or research service providers such as Google (3) statistical analysis service companies (4) survey service companies (5) companies providing marketing services, advertising media, design, creation and communications; (6) campaign, event and marketing providers; (7) administrative service providers; and (8) storage and cloud services providers.

(e) External consultants, including lawyers, technicians and auditors who assist Häfele in conducting business or exercising legal claims.

(f) Third parties as required by law: In some cases, Häfele may be required to disclose or share your Personal Data in order to comply with laws or regulations. This includes law enforcement agencies (such as the Department of Land Transport, the Revenue Department, Office of the Consumer Protection Board), courts, law enforcement, government agency or other third parties. If Häfele believes it is necessary to comply with a legal or regulatory obligation or to protect the rights of Häfele third party rights or personal safety or to detect, prevent, or resolve fraud, security, or security issues.

(g) Hospitals and rescue teams: Your Personal Data may be disclosed in an emergency to protect your interests.

(h) Assignee of rights and/or obligations: In case of business rehabilitation merger, business transfer, in whole or in part, sale, purchase, joint venture, grant, transfer or disposition of part or all of Häfele's business; property or stock or similar transactions. Third parties as assignees of Häfele shall comply with this Privacy Policy to protect your Personal Data.

(i) Other sources of data publicly available, such as websites, advertisements and/or social media platforms.

Transfer of Personal Data

1. Häfele operates globally and may transfer Personal Data collected from you to related companies or overseas affiliates to provide services for the purposes stated above. Häfele may need to disclose your Personal Data to third parties located abroad for the purposes set out in this Privacy Policy. Countries to which Häfele may transfer your Personal Data include but are not limited to Germany. The disclosure of Personal Data or the transfer of such Personal Data may be done with your consent unless Häfele has set a separate privacy policy for sending or transferring Personal Data to Data Controllers or Data Processors located abroad and affiliated companies for business operations or joint business. If such Privacy Policy has been reviewed and approved by the Office of the Personal Data Protection Commission or can rely on other legal bases (for example, to comply with the terms of the contract between you and Häfele and other persons for your benefit) as permitted by applicable law, Häfele shall be able to do so without your consent.
2. Please note that the country from the perspective of the data protection supervisory authority in Thailand, there may not be an 'equivalent Personal Data protection standard' as required by the data protection regulator in Thailand. Although the collection, retention, disclosure and use of your Personal Data by Häfele shall still be governed by the provisions of this Privacy Policy. Therefore, if your Personal Data is transferred to a destination country whose Personal Data protection standards are inadequate to those under applicable law. Häfele shall take the necessary steps to protect Personal Data transferred to third parties abroad in order to obtain the same level of protection as Häfele protects your Personal Data and in accordance with the law in force at that time.

Retention and period of retention of Personal Data

Häfele shall retain your Personal Data for the period reasonably necessary to fulfill the purposes set out in this Privacy Policy. If legal or disciplinary action is taken, Häfele may need to keep your Personal Data until the processing is completed (this includes the possible timeframe for filing an appeal). Thereafter, your Personal Data will be deleted or archived as permitted by applicable law.

Data Subject's rights

You have the right to do the following:

1. Right to withdraw consent: You have the right to withdraw your consent to the processing of Personal Data that you have given to Häfele for the duration of your Personal Data being with Häfele.
2. 2. Right of access to Personal Data: You have the right to access your Personal Data and request that Häfele make a copy of such Personal Data for you including asking Häfele to disclose the acquisition of Personal Data that you have not given consent to Häfele.
3. 3. Right to rectify Personal Data: You have the right to ask Häfele to correct inaccurate data or add incomplete data.
4. 4. Right to erasure of Personal Data: You have the right to request that Häfele delete your data for certain reasons.
5. 5. Right to suspend use of Personal Data: You have the right to suspend the use of your Personal Data for certain reasons.
6. 6. Right to portability of Personal Data: You have the right to transfer your Personal Data that you have provided to Häfele to another Data Controller or yourself for certain reasons.
7. 7. Right to object to the processing of your Personal Data: You have the right to object to the processing of your Personal Data for certain reasons.

You can contact the Personal Data protection officer/office staff of Häfele in order to submit a request to perform the above rights (Contact details appear in the topic "Contact" below)

However, you do not have to pay any cost. In pursuing the above rights Häfele shall consider and notify the result of your request within 30 days from the date Häfele receives such request.

Marketing and promotional activities

During the use of the service, Häfele may send you news about marketing activities and marketing promotion, products, and services of Häfele that Häfele thinks you may be interested in for the benefit of providing services to you with full efficiency. If you have already agreed to receive such data from Häfele, you have the right to revoke such consent at any time. You can revoke your consent to receive data at phone: (02) 768-7171 , (02) 741-7171 or fax: (02) 741-7272.

Cookies

Cookies are text files placed on your computer that are used to store a detailed log of your Internet usage or your browsing behaviurs. Häfele collects information about all visits to the website through cookies or similar technologies. The types of cookies that Häfele choose to use are as follows.

1. Necessary basic Cookies to enable the main functionality of the website. This includes accessing secure areas of the website, without this cookie, the website will not function properly and it will be available by default settings without being able to disable it.
2. Analytics Cookies. This will help the website to understand your usage patterns and will improve the user experience by collecting information and reporting the results of your use.
3. Marketing Cookies. It is used to track your behaviour through the website to deliver advertisements tailored to individual users and to enhance advertising effectiveness for publishers and third party advertisers.

For the Personal Data that Häfele collects from the use of cookies, Häfele will process this data in accordance with this Privacy Policy.

You can disable cookie settings by accessing your browser settings and adjusting your privacy settings to limit future cookie collection or learn more about cookies in our Cookie Policy.

Changes to Privacy Policy

Häfele shall review the Privacy Policy on a regular basis to ensure compliance with applicable practices and laws and regulations. Häfele shall update changes made to the Privacy Policy to relevant parties on the Häfele website as soon as possible.

Contact

Data Controller details

Hafele (Thailand) Limited
Contact place: The head office is located at No. 57 Soi Sukhumvit 64, Sukhumvit Road, Phra Khanong Tai Subdistrict, Phra Khanong District, Bangkok 10260.
Phone: (02) 768-7171 , (02) 741-7171 or Fax: (02) 741-7272
Email: info@hafele.co.th
Website: www.hafelethailand.com

Violations

Violation of this Privacy Policy may result in disciplinary action, including but not limited to, termination of employment or contract and criminal and/or civil penalties in accordance with applicable law.