Client Privacy Notice

1. General Information

PDLegal Asia (Thailand) Company Limited ( “we”, “our” or “us”) has prepared this privacy notice (“Privacy Notice”) to describe our standard practice and how we handle personal data of our clients, potential clients, and any persons related to our clients in accordance with the Personal Data Protection Act B.E. 2562 (2019), including any ancillary laws related and any amendment which may be made thereto (“Applicable Data Protection Laws”).

Under this Privacy Notice, we collect and process personal data from the following:

“Client”, which means any individual or natural person who we provide our services to, or personnel of corporate clients which may include, but not limited to, employees, authorized person, directors, shareholders, contact persons of our corporate clients, visitors and users of our websites and our online properties, and any other individuals about whom we obtain personal data in connection with our services including any potential client or any other persons having similar characteristics, such as participants of our business events, visitors, persons who make contact to request for information or services from us, etc.

“Persons related to the Client”, which means any individual or natural person, or personnel of corporate clients which may include, but not limited to, employees, authorized person, directors, shareholders, representatives, contact persons of our corporate clients, whose personal data is processed by us in connection with the provision of services to our non-individual or entity Clients, including any other persons having similar characteristics, as well as persons whose personal data appears in relevant documents and processes, such as witnesses, check payers, messengers, consignees, individuals relating to counterparties, target companies or any other similar entities, etc.

In this Privacy Notice, any reference to the “Client” shall be construed so as to include the “Persons related to the Client” and the terms “you” “your” or “yours” shall have a corresponding meaning.

2. Personal Data Collected

We may collect and process the following data:

2.1 Identity Information, name, surname and nickname, gender, title, organization, occupation, position, job title and responsibilities, authority, marital status, government issued documents or information (e.g., national identification card, passport, work permit, visa, entry card, house registration, tax identification number, and/or other governmental document/number), photo, signature, curriculum vitae (CVs/resume), assets, working experiences, educational background, family background, and photographs or videos, etc.

2.2 Contact information, such as telephone number, fax number, e-mail, home address, work address, delivery address, billing address and user IDs for communication applications (e.g., Telegram, Line, WhatsApp, WeChat, KaKao) or other social media platforms (e.g., LinkedIn), etc.

2.3 Organizational information, such as name of company you work for, your company’s affiliated agency or organization, your job title, position, division, and department, etc.

2.4 Financial information, such as bank account details, personal data contained in invoices, tax invoices, receipts, and other financial details, etc.

2.5 Information contained in documents, contracts or agreements, such as personal data contained in the original and/or copy of documents you provided to us, including the national identification card (or other similar forms of documentation), passport, visa document, work permit, house registration book, power of attorney, company’s affidavit, memorandum of association, articles of association (or other forms of similar documents), list of shareholders, VAT registration certificate, fee proposals, letters of engagement, or any other documents or agreements having similar characteristics, etc.

2.6 Sensitive Personal Data, such as health data (i.e., results of ATK/PCR tests for COVID-19), religious beliefs, criminal records, etc.

2.7 Technical information, such as log file and IP Address, etc.

2.8 Other information, such as license plate number, type of vehicles, records of mail/courier delivery and receipts, and records of e-meetings and telephone conversations, etc.

3. How Data is Collected

3.1 Typically, we collect your personal data in the following ways:

(a) Directly from you
We may directly collect your personal data from you, for instance:

• • When you contact us, whether in written or oral communications, and whether by face-to-face interaction or using any other channels such as telephone, e-mail, mail, website, or any other media platforms;
  • When you express an intention to use our services, engage or enter into contracts, letter of engagements, assignment letters, and/or confidentiality agreements or non-disclosure agreements with us;
  • When you deliver documents containing personal data to us; or
  • When you attend business events, or any other activities organized by us, on our behalf or in which we participated.

(b) From other sources or third parties
We may collect your personal data from other sources or third parties, such as:

• • Your contact persons, secretaries, representatives, personnel, attorneys-in-fact and/or other authorized persons;
  • Our business partners or service providers, such as mailing services and payment services;
  • Our regional offices and affiliates across our global network, including in Singapore, Malaysia, and the United Kingdom; or
  • Government authorities, public agencies, courts of justice.

In some cases, we may collect your personal data from public sources which provide information relating to your business, irrespective of whether you have disclosed the personal data by yourself or have provided consent to those sources to disclose your personal data.

When you are an individual relating to the Client’s counterparties, target companies or any other similar entities, we may collect your personal data from the Client or Persons related to the Client (as the case may be). For example, when the Client or Persons related to the Client provide information and/or documents containing your personal data to us in connection with the provision of our services.

3.2 Where we have previously collected your personal data before the Applicable Data Protection Laws have become effective, we will continue collecting and using your personal data only for the original purposes of such collection. Nevertheless, if you do not intend for us to continue collecting and using your personal data and if we have relied on your consent as a basis for processing your personal data, you may contact us by using the contact details provided at the bottom of this Privacy Notice to request for the timely withdrawal of your consent. We reserve the right to consider your request for the withdrawal of consent and proceed in accordance with the Applicable Data Protection Laws.

4. Purposes and Legitimate Bases for Personal Data Processing

4.1 We process your personal data for the following purposes ( “Purposes”) and under the following legal bases: