PRIVACY POLICY

In compliance with Personal Data Protection Act B.E. 2562 (2019) (“Thailand PDPA”) on the protection of personal data and the handling of the personal data, please read this privacy policy (“Privacy Policy”) carefully to understand our policies and practices regarding your personal data (as defined in Thailand PDPA) (“Personal Data”) and how we will treat it.

Asian Legal Solutions Co., Ltd. including its affiliated companies (“Legal Asean”, “We”, “we” “us”, “OUR”, “our”, “ours”) are committed to protect your Personal Data and adhere with the Thailand PDPA. Therefore, Legal Asean has set out this Privacy Policy so that you can be assured that your Personal Data entrusted with us will be collected and processed to meet your needs and in accordance with the laws.

This Privacy Policy applies to individuals who interact with our legal professional services as clients and/or counterparties; individuals who interact with us for other purposes such as personals recruitments; or individuals who interact with us in order to provide services and/ or goods to us (“You”, “you” “Your”, “your” “yours”). This Privacy Policy is to inform you, as a data subject, to be aware of the purposes and details of the collection, usage and/or disclosure of your Personal Data as well as your legal rights in connection with Personal Data.

This Privacy Policy covers both our online and offline data collection activities, including Personal Data that Legal Asean collects through our various channels such as websites, web-based survey administration software, apps, third party social network, and events. Please note that Legal Asean might aggregate personal data from different sources. As part of this, we combine Personal Data that were originally collected by different Legal Asean entities or partners.

If you do not provide necessary Personal Data to us (Legal Asean will indicate to you when this is the case, for example, by making this information clear in our registration forms), Legal Asean may not be able to provide you with our services. This Privacy Policy can change from time to time.

1. SOURCES OF PERSONAL DATA.

   Legal Asean collects your Personal Data from or about you, through the methods described in Section 2 from the following sources:

   1. Offline meet-up. Interaction and communication provided between you and us during the physical meeting;
   2. Legal Asean’s websites. Site that Legal Asean operates under our own domains/URLs and mini-sites;
   3. E-mail, text and other electronic messages. Interactions with electronic communications between you and Legal Asean;
   4. Offline-Online registration forms. Printed or digital registration and similar forms that Legal Asean collect via, for example, postal mail, events or web-based survey administration software like Google Forms and Microsoft Forms and other similar methods;
   5. Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third-party website, we may receive information about that interaction);
   6. Data We create. In the course of our interactions with you, Legal Asean may create Personal Data about you (e.g. records of your hiring our legal professional services, records of your employment); and
   7. Data from other sources. Third party social networks (e.g. such as Facebook, Google), market research (if feedback not provided on an anonymous basis), third party data aggregators, public sources and data received when we acquire other companies.

2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT.

   Depending on how you interact with us (online, offline, over the phone, etc.), the matters you engage or prospectively to engage us and matters that we engage you, Legal Asean collects various types of information from you, as described below.

   1. Personal contact information.
      This includes any information you provide to Legal Asean that would allow Legal Asean to contact you, such as your name, postal address, e-mail address, social network details, mobile phone or phone number;
   2. Personal identification information.
      Any Personal Data which enables identification of you such as name, date of birth, gender, marital status, military status, nationality, data on your identification card/passport, data on your driving license, tax identification number, employment-related data (such as position, workplace, signature, work experience, educational background, skills, professional qualifications, professional license number, compensation and benefits, curriculum vitae and resume, work and leave records and data communicated or stored on Legal Asean’s system related to your work and/or employment), voice, still picture, moving picture, financial data (such as bank account details income, expenses, financial history, assets, transaction information such as financial statements, payments, borrowings and investments);
   3. Emergency contact and business reference related information.
      Legal Asean may collect the Personal Data of your contact persons which you have provided for emergency purpose and also may collect the Personal Data of your business reference for reference purpose;
   4. Account login information.
      Any information that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password in unrecoverable form, and/or security question and answer.
   5. Information from computer/mobile device.
      Any information about the computer system or other technological device that you use to access one of our websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Legal Asean website or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.
   6. Market research and clients feedback.
      Any information that you voluntarily share with us about your experience of using our legal professional services.
   7. Third party social network information.
      Any information that you share publicly on a third-party social network or information that is part of your profile on a third party social network (such as Facebook or LinkedIn) and that you allow the third party social network to share with us. You can learn more about how your information from a third-party social network is obtained by Legal Asean or to opt-out of sharing such social network information by visiting the website of the relevant third-party social network.
   8. Sensitive Personal Data.
      Collecting and processing Sensitive Personal Data (as defined by Thailand PDPA) such as race, religion, criminal records, disability, and health data (blood type, temperature, symptoms, biometric data and disability) are not primary course of our business operation. Legal Asean will collect, process or disclose such Sensitive Personal Data only when Legal Asean has obtained explicit consent from you or where necessary for Legal Asean as permissible under applicable laws.

   (Unless otherwise specified in this Policy, Personal Data and Sensitive Personal Data about you above will be collectively called “Personal Data”)

    

3. PERSONAL DATA OF CHILDREN/ADJUDGED INCOMPETENT OR QUASI-INCOMPETENT PERSON.

   Legal Asean does not knowingly collect Personal Data from (i) children below the age of 20, (ii) adjudged incompetent or quasi-incompetent person by the Court’s order. Legal Asean may collect Personal Data about children below the age of 20 years of age, adjudged incompetent or quasi-incompetent person by the Court’s order from the parent or legal guardian directly, and with that person’s explicit consent.

4. LOG FILES AND WEB BEACONS.

   1. Log Files.
      Legal Asean collects information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help us to troubleshoot errors, improve performance and maintain the security of our websites.
   2. Web Beacons.
      Web beacons are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to us. The information collected via web beacons will include information such as IP address. We will use web beacons on our websites or include them in e-mails that We send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting.

5. PURPOSE OF PROCESS YOUR PERSONAL DATA

   The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual as it will be related to each individual based on your interaction on case by case basis.

   1. Contractual Basis.
      1. Providing Legal Professional Services.
         We use your Personal Data to process and conduct all related legal professional services engaged by you to meet your purpose under your contract with Legal Asean or to take steps at your request prior using our services;
      2. Conducting activities in relation to Legal Asean’s commitments and obligations under your employment contracts.
         We use your Personal Data to process, conduct and maintain employees/employment records, employees’ health and safety within the workplace and the working environment, administration of welfare and benefit programs (including cooperative related matters), processing your work permits and visas, performance management, talent management and succession planning; and
      3. Conducting activities in relation your commitment and obligations under agreements executed between you and Legal Asean.
         We use your Personal Data to arrange for execution of the agreements and any other necessary documents to achieve business transactions between you and us including without limitation to acquire goods and/or services from you, conduct due diligence and/or verification process; performing our contractual obligations, including without limitation to arrange for payments, claim for expenses, and/or refunds; to arrange for and provide you with necessary trainings and required assistance; to create, record and maintain your information including Personal Data in our system for administration purposes including to open a new account for you in order to proceed with the transactions between us, communicate with and contact you regarding our arrangement and transactions, ensure health and safety within the workplace and premises of Legal Asean and comply with internal/external audits, standards, workplace environment safety and security and requirements, and where applicable, to ensure that you are in compliance with any or all such requirements and obligations.
   2. Legal Obligations.
      To Comply with relevant or applicable laws for Legal Asean such as governmental reporting regulations and Legal Asean’s compliance with its legal obligations. If we are required to collect, use and/or disclose your Personal Data to meet our legal obligations or enter into an agreement with you, Legal Asean not be able to provide (or continue to provide) our services to you if we cannot collect your Personal Data when requested.
   3. Other purposes.
      Legal Asean may use your Personal Data for the followings:
      1. Conducting activities in relation to the recruitment purposes.
         We use your Personal Data to process and conduct the recruitment procedure such as assessing and determining your qualifications, suitability and eligibility for the position, verifying the accuracy of the information, checking background for compliance purpose, making decision on the approval or refusal of the candidate, preparing job offer/proposal for successful candidate, communicate with and contact you regarding the status of job application and to arrange for the interview sessions and necessary testing, arrange for health check for and/or carry out criminal record check as part of the recruitment process, prevent and detect fraud or criminal activity; and ensure health and safety within the workplace and premises of Legal Asean;
      2. Marketing and advertorial related activities.
         We use your Personal Data for conducting marketing and advertisement such as serving notification of workshops, speeches, seminars, events (via mails, fax, e-mails, or other means), publications, articles, other legal information and/or greeting cards.
      3. Risks management related activities.
         We use your Personal Data to process and conduct in order to monitor and manage risks within organization including to referring such tasks to affiliated companies of Legal Asean, to prevent, respond, and minimize potential risks arising from corruption, cyber threat, debt default or contractual breach, law violations including sharing Personal Data to enhance work standards of affiliated companies of Legal Asean in order to prevent, respond, and minimize the above risks.
      4. Legal reasons or merger/acquisition.
         In the event that Legal Asean and its assets are acquired by, or merged with, another company including through bankruptcy, we will share your Personal Data with any of our legal successors.
         We will also disclose your Personal Data to third parties on the followings when it is required laws
      5. Any other purposes incidental to those listed above in this Section 5.

    

6. DISCLOSURE OF YOUR PERSONAL DATA

   Legal Asean may disclose your Personal Data to other person to the extent permissible under your consent or law. The persons or entities receiving such data will collect, use, and/or disclose the Personal Data to the extent permissible under your consent or related to this Privacy Policy. In addition to the Legal Asean entities mentioned in the data controllers in Section 11, Legal Asean shares your Personal Data with the following types of third-party organizations:

   1. Service providers.
      There are third party service providers assisting us in operating our business (e.g. banking and payment processing, accountancy, identity and other information verification, website operation, market research companies, support services, website and application developments, data analysis, recruitment processing, legal advisory, etc.). Service providers, and their selected staffs, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.
   2. Credit reporting agencies/debt collectors.
      Credit reporting agencies and debt collectors are external entities assisting Legal Asean to verify your creditworthiness (in particular for orders with invoice) or to collect outstanding invoices (if any), we may share your Persona Data to the extent permitted by applicable law.
   3. Third party recipients using Personal Data for legal reasons or due to merger/acquisition.
      Your Personal Data may be disclosed to third parties for legal reasons (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreements.  In the event that Legal Asean or its assets are acquired by, or merged with, another company including through bankruptcy, we will share your Personal Data with any of our legal successors.

7. RETENTION OF YOUR PERSONAL DATA

   Legal Asean ensures that your Personal Data is retained with us for the minimum necessary period for purposes set of in Section 5 in this Privacy Policy, unless law requires or permits longer retention period. The criteria for determining the retention period for your Personal Data are:

   1. Copies of your Personal Data in a form that allows for identification shall be retained only for as long as: (i) Legal Asean maintain an ongoing relationship with you and (ii) your Personal Data are necessary in connection with the purposes set out in Section 5 of this Privacy Policy and we have a valid legal basis;
   2. The duration of: (i) any applicable limitation period, and (ii) an additional 2 months following the end of the applicable limitation period; and
   3. In addition, if any relevant legal claims are brought, your Personal Data may be processed for such additional time necessary in connection with that claim.

   During the periods noted in Sections 7.2 (i) and (ii), our processing of your Personal Data will be restricted to storage and/or maintain the security of, those data, excepts to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.

   Once the periods in paragraphs (a), (b) and (c) above, each to the extent applicable, have concluded, we will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymize the relevant Personal Data.

8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA.

   Your Personal Data will be kept in confidential and secure through our following appropriate protocols. Moreover, our executives, staffs, employees, contractors, agents, advisers and data receivers are obligated to keep the Personal Data in confidence pursuant to confidentiality measure provided by us. This measure does not apply to any information you choose to share to the publics.

   1. Accessibility to your Personal Data.
      Only the authorized staffs, agents and representative will process your Personal Data, on a need-to-know basis, depending on the specific purposes for which your Personal Data have been collected.
   2. Storage of your Personal Data.
      Your Personal Data will be stored in operating environments that use reasonable security measures to prevent unauthorized access. Legal Asean will do our best effort to protect your Personal Data, however, transmission of information via the Internet is, unfortunately, not completely secure therefore, we cannot guarantee the security of the data during transmission through our websites/apps and other similar measures.
   3. Expected measured to be taken from you:
      You as the data subject are significant player and being important part to ensure that the Personal Data is kept in safe and secure. Please ensure that account password of the online account created with us are difficult for others to guess and never been revealed to anyone. Keeping the password of such account in confidential and using of such account are your responsible. Please ensure when you use a shared and/or public computer, mobile devices, laptop, tablet or any other similar devices, not to select to have your username or password of the account created with us remembered. Logging out of your account every time you leave your computer, mobile devices, laptop, tablet or any other similar devices.
   4. Transfer of your Personal Data.
      Regarding to the nature of our business as international legal professional service providers, transfer of your Personal Data may be needed to third parties as noted in Section 6 above, in connection with the purposes set out in Section 5 of this Privacy Policy. We may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. However, the standard contractual clause to protect your Personal Data approved by Thailand Personal Data Protection Commission under Thailand PDPA will be put in place (if any)
      and/or (ii) will rely on your consent (where permitted by law).

9. YOUR RIGHTS

   Your rights described here are legal rights that you should be informed, unless otherwise stipulated by laws. You may exercise any of these rights within legal requirements and policies at the present or as amended in the future as well as regulation set out by us.

   1. The right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data;
   2. The right to request deletion, the portability, correction or revision of your Personal Data;
   3. The right to limit the use and disclosure of your Personal Data;
   4. The right to revoke consent to any of our data processing activities;
   5. The right to object, on grounds relating to your particular situation, to the use of your relevant Personal Data by us, or on our behalf;
   6. The right to object to the processing of your relevant Personal Data by us; and
   7. The right to request the transfer of your Personal Data to another company.

   Exercising your rights above can be done by sending us an e-mail or postal mail to us as your Data Controller as mentioned in Section 11 attaching a copy of your certified true and correct ID card, passport, or any other similar and equivalent details (where requested by us and permitted by law). In case you are under 20 years old, or your legal contractual capacity is restricted, your father and mother, guardian or representative may request to exercise the rights on your behalf. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.

   Please note that any identification information provided to Legal Asean will only be processed in accordance with, and to the extent permitted by applicable laws. If Legal Asean denies the request, we will inform you of the reason.

   Please note that, in certain circumstances, Legal Asean will not be able to delete your Personal Data without also deleting your user account. It may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. Retaining some of your Personal Data to satisfy our business needs may be permitted by applicable laws.

   In case your concerns are not resolved you also have the right to complain to Thailand Personal Data Protection Commission under Thailand PDPA.

10. CHANGES TO THIS PRIVACY POLICY.

    Legal Asean reserves the right to make changes to our practices in handling your Personal Data and this Privacy Policy at any time, please check back frequently to see any updates or changes to our Privacy Policy.

11. DATA CONTROLLERS, DATA PROTECTION OFFICER & CONTACT.

    If you have any suggestions or inquiries regarding collection, usage, process and/or disclosure of your Personal Data as well as a request to exercise your rights under this Privacy Policy, you may contact us as the Data Controller and/or contact the Data Protection Officer via the following channel:

    1. Data Controllers: Asian Legal Solutions Co., Ltd.
       • Address:

         43/6 Sukhumvit 11 (Chaiyos) Alley, Sukhumvit Road, Klongtoey Nue Sub-district, Wattana District, Bangkok, 10110, Thailand.
       • Telephone Number: +662 121 7782
       • Email address: [email protected]
    2. Data Protection Officer: Data Protection Officer of Asian Legal Solutions Co., Ltd.
       • Address:

         43/6 Sukhumvit 11 (Chaiyos) Alley, Sukhumvit Road, Klongtoey Nue Sub-district, Wattana District, Bangkok, 10110, Thailand.
       • Telephone Number: +662 121 7782
       • Email address: [email protected]