Privacy Notice for Shareholders L.P.N. Development Public Company Limited
L.P.N. Development Public Company Limited (the “Company”) recognizes and values the importance of protecting the personal data of shareholders (“You”) and/or your proxies. The Company has prepared this Privacy Notice to inform you of the details regarding the collection, use, and disclosure of your personal data in your capacity as a data subject, in accordance with the personal data protection law. The details are as follows:
1. Personal Data to be Collected, Used, and Disclosed by the Company
(1) Identification information, such as name, surname, national identification card number, passport number, information appearing on the national identification card or passport, date of birth, gender, age, occupation, nationality, photographs, and video images.
(2) Contact information, such as address, email address, and telephone number.
(3) Financial or securities information, such as bank account information, number, class, or type of shares or securities, name of securities holder, and securities registration number.
(4) Communication records with the Company, such as images and sound recordings, or other communications between you and the Company, etc.
(5) Other personal data, such as opinions or suggestions.
The Company does not intend to collect, use, or disclose information regarding religion or blood type appearing on your and/or your proxy’s identification card or passport, including copies of such documents. Therefore, the Company kindly requests that you and/or your proxies cross out or conceal such personal data before submitting the documents to the Company. If you do not cross out or conceal such personal data, the Company will do so on your behalf. This action shall not be deemed as the collection of such personal data. In the event that the Company is unable to conceal such personal data due to technical limitations, the Company will collect and use such personal data solely as part of identity verification documents.
2. Purposes of Collection, Use, and Disclosure of Personal Data
The Company is required to collect, use, and disclose your personal data for the purpose of organizing the shareholders’ meeting and conducting activities related thereto, based on the following legal bases:
| Item | Purpose | Legal Basis |
|---|---|---|
| 1 | To organize shareholders’ meetings in accordance with applicable laws; administer the shareholders’ register; verify identities; record and prepare minutes of the meeting; distribute dividends; and comply with orders of competent authorities as required by law, including compliance with laws governing securities and exchange, anti-money laundering, taxation, the Public Limited Companies Act, and/or other relevant laws. | Legal Obligation Legitimate Interests |
| 2 | To participate in and manage shareholders’ meetings; analyze data and create a shareholders’ database; and facilitate registration and access to the Website or Applications provided by the Company for shareholders (if any). | Legitimate Interests |
| 3 | To record images, audio, and/or video during the meeting; for the Company’s dissemination or public relations purposes; or for the benefit of the meeting participants. | Legitimate Interests |
| 4 | To carry out activities related to investor relations organized by the Company, including conducting surveys, for the purpose of analysis and improvement of the Company’s operations. | Legitimate Interests |
| 5 | To arrange food and beverages during shareholders’ meetings or take any necessary actions to prevent harm to your life, body, or health. | Vital Interests |
| 6 | To maintain a database to support the Company’s operations relating to the provision of benefits to you as a shareholder of the Company or as a stakeholder database. | Legitimate Interests |
| 7 | To support risk management and internal control or corporate governance within the Company. | Legitimate Interests |
| 8 | For the establishment, exercise, or defense of legal claims, including legal proceedings and enforcement of judgments. | Legitimate Interests |
| 9 | In addition to the purposes specified in Items 1–8, the Company may collect, use, and disclose your personal data by obtaining your additional consent from time to time, whether given verbally or in writing. | Consent |
*If you do not provide the necessary personal data, the Company may be unable to carry out the purposes specified herein, and you may lose certain rights or benefits as a shareholder of the Company.*
The Company will collect, use, and disclose your personal data only to the extent necessary and in compliance with applicable laws.
3. Sources of Personal Data
The Company shall collect your personal data through inquiries, registrations, or by requesting you to complete paper or electronic forms, either directly from you or, where necessary, from other sources, such as government agencies, the securities registrar, the Company’s website, the Company’s information systems, and meeting service providers.
4. Use of Cookies
When you access the Company’s electronic media, such as applications, the Company’s website, or its information technology systems, the Company uses cookies to collect personal data in accordance with the Cookie Policy available at www.lpn.co.th/นโยบายความเป็นส่วนตัว
5. Retention Period of Personal Data
The Company will retain your personal data only for as long as necessary to fulfill the purposes specified in Item No. 2, or for the duration of the applicable statutory limitation period, or as required by relevant laws governing the retention of such documents. Upon the expiration of such period, the Company will implement procedures to delete or destroy your personal data.
6. Disclosure and Transfer of Personal Data
The Company may disclose, send or transfer your personal data to external parties as permitted under the Personal Data Protection Act for the purposes specified in Item No. 2, as follows:
(1) Government agencies or regulatory authorities overseeing the Company
(2) External service providers engaged by the Company
(3) Business or professional advisors
(4) Subsidiaries and/or affiliated companies to assist in carrying out the purposes specified above
In this regard, the Company may disclose, send, or transfer your personal data to entities, persons, or organizations located outside Thailand, as permitted under the Personal Data Protection Act.
7. Security Measures for Personal Data
The Company has implemented appropriate measures to ensure the security of your personal data, in accordance with the Company’s Information Security Policy. These measures are designed to prevent the loss, unauthorized access, destruction, use, alteration, modification, or disclosure of personal data.
8. Your Rights
As the data subject, you are entitled to the following rights under applicable laws:
(1) The right to be informed about the processing of your personal data;
(2) The right to access and obtain a copy of your personal data;
(3) The right to request rectification of your personal data to ensure that it is accurate, complete, and up to date;
(4) The right to object to the collection, use, or disclosure of your personal data, unless the Company has lawful grounds to reject your request;
(5) The right to withdraw your consent at any time;
(6) The right to request erasure or anonymization of your personal data, unless the Company has lawful grounds to reject your request;
(7) The right to data portability, including the right to request that your personal data be transferred to another data controller or to receive personal data that the Company has sent or transferred to another data controller directly, unless the Company is unable to do so due to technical reasons;
(8) The right to restrict the use of your personal data.
You also have the right to lodge a complaint with the Personal Data Protection Committee or the Office of the Personal Data Protection Committee if the Company fails to comply with the Personal Data Protection laws.
9. Changes to This Privacy Notice
The Company may amend or update this Privacy Policy from time to time. Any changes will be notified through www.lpn.co.th/นโยบายความเป็นส่วนตัว
10. Contact Information
If you have any inquiries or require further information regarding this Privacy Notice, or if you wish to exercise your rights as a data subject, you may contact:
L.P.N. Development Public Company Limited
1168/109 Lumpini Tower, 36th Floor, Rama IV Road, Thung Maha Mek Subdistrict, Sathon District, Bangkok, Thailand
Tel: 02-689-6888
Email: dpo@lpn.co.th