Montri Transport Corporation Public Company Limited
PERSONAL DATA PRIVACY POLICY (Version 1.0 as of December 29, 2022)
Montri Transport Corporation Public Company Limited (“Company”) realizes the importance of personal data protection and has compliance and management of Personal Data which are consistent with Personal Data Protection law and related laws. The Company would like to notify you of the Company’s compliance with the Personal Data Protection Act, B.E. 2562 (2019) as follows:
- 1. The Collection, use and disclosure of Personal Data
Company will collect personal data relating to a Person, which enables the identification of such Person, whether directly or indirectly through registration on www.montri.co.th or any online platform, application, cookie, or other company's social media channels as follows:
- Personal information such as name, surname, age, date of birth, marital status, identification number passport number
- Contact information such as residence, workplace, telephone number, email address, Line ID
- Device or device information such as IP Address MAC Address Cookie ID
- Other data such as website usage, audio, still images, and movies and any other information that is considered personal data under the Personal Data Protection Laws.
In the case where the owner of personal data is a minor (School bus riders, students), if the minor is over the age of 10 but has not yet reached the age of majority and is unable to take any actions under the law on their own, and the actions in question require the disclosure of the minor's personal data, the consent of the minor's parent or guardian or the person with legal custody of the minor must be obtained directly, or the minor must notify their parent or guardian or the person with legal custody for consent to be given for the actions in question to the company. In the case where the minor is under the age of 10, the parent or guardian or the person with legal custody of the minor shall act on behalf of the minor (according to section 20 of the Personal Data Protection Act, B.E. 2562 (2019)).
- 2. Purposes for the collection, use, and disclosure of Personal Data
The company collects, uses, and discloses your Personal Data for the following purposes:
- For the improvement of the Company’s website or application and any other Company's social media channels
- For operating the Corporate bus and School bus transportation
- For providing a tracking system for the transport service
- For analyzing the Personal data to deliver a better experience for the users.
However, should any modifications to the stated purposes for the collection of Personal Data subsequently occur, the Company will duly inform you as well as fulfill other legal obligations, including the recording as evidence of the amendment of the purposes stated in this Policy.
- 3. Protection of Personal Data
The company understands the importance of appropriately safeguarding the information you provide to us. It is our practice to protect the confidentiality of this information, limit access to this information to those with a business need, and not disclose this information unless required or permitted by law.
The company has security practices and procedures in place to protect the data entrusted to us. These procedures and related standards include limiting access to data and regularly testing and auditing our security practices and technologies.
All employees are required to complete privacy, security, ethics, and compliance training. The company also offers a wide variety of other training to all employees and temporary workers to help us achieve our goal of protecting your information.
- 4. The Personal Data retention period
The company will retain your Personal Data only for the necessary duration and will collect, use and disclose your Personal Data, as defined in this Policy, in accordance with the duration criteria, namely the period during which you are still related to the Company as a client, and may still retain your Personal Data as long as needed for legal compliance or as per legal prescription, for the establishment of legal claims, legal compliance or exercise of legal claims, or defense of legal claims, or for other purposes in accordance with policies and the internal regulations of the Company.
If it is not possible to specify the Personal Data retention period, the Company will retain the Personal Data as may be expected per data retention standards (such as the longest legal prescription of 10 years).
- 5. Your Rights as a Data Subject
As a Data Subject, you have the rights as prescribed in the Personal Data Protection Act, B.E. 2562 (2019) and other rights as follows:
5.1 Right to withdraw consent
You have the right to withdraw consent for the processing of your Personal Data as submitted to the Company, but not if the consent withdrawal is restricted by law or by the contract of benefit to you as a Data Subject. However, the withdrawal of consent shall not affect the processing of Personal Data to which you have already legally consented.
5.2 Right to access the Personal Data
You are entitled to request access to and obtain a copy of your Personal Data, under the Company’s care and responsibility, as well as to request the disclosure of the acquisition of your Personal Data without your consent.
5.3 Right to request for sending or transferring the Personal Data (Right to data portability)
You have the legal right to request the Company to transfer your Personal Data.
5.4 Right to object to the collection, use, or disclosure of Personal Data
You have the right to object to the processing of your Personal Data, namely the collection, use, or disclosure of your Personal Data as prescribed by law.
5.5 Right to request the erasure of Personal Data (Right to be forgotten)
You have the legal right to request the Company to erase, destroy, or to anonymize your Personal Data.
5.6 Right to restrict the use of Personal Data.
You have the legal right to request the Company to suspend the use of your Personal Data.
5.7 Right to request for the correction of the Personal Data
Should you discover that your Personal Data kept by the Company is not correct or has been modified, you have the legal right to request the Company to correct them so that your Personal Data is accurate, up-to-date, complete, and will not incur any misunderstandings.
5.8 Right to be informed in case of the modification of the Privacy Notice
The Company may consider and modify as appropriate this Privacy Notice to ensure that your Personal Data is well protected.
5.9 Right to Complain
You have the right to complain to authorized officials as prescribed by the Personal Data Protection Act, B.E. 2562 (2019) in case of the Company’s infringement or non-compliance with the Act. In the event that the Data Subject lodges their request to exercise their rights as prescribed by the Personal Data Protection Act, B.E. 2562 (2019), upon reception of the such request, the company will further proceed within the duration of time as prescribed by the Act. However, the Company reserves the right to deny or not to proceed with the request as prescribed by law in the case that the Data Subject has chosen to provide to the Company only certain Personal Data which may cause the Company not to be able to provide full services. Moreover, the Company may not be able to collaborate with or provide services to the Data Subject if they do not consent to the provision of information as required by the Company.
- 6. The Disclosure of Personal Data to a Third Party
The Company may have the need to disclose Personal Data to its subsidiary or to other persons or business units that are strategic allies in Thailand or in a foreign country cooperating with the Company in the procurement of various products or services, or out of necessity as prescribed by terms and conditions of the Company, or in case of reorganization, merging or sales of the Company and may require the disclosure of the Personal Data to Thai authorities or Public Organizations concerned as prescribed by law or by court order or by the order of authorized officials for which the Personal Data will be kept confidential, either in paper form or electronic form, including during its transfer.
However, in case of an international transfer of Personal Data, the Company will strictly comply with the Personal Data Protection Act, B.E. 2562 (2019).
- 7. Amendment of the Policy and Guideline on Personal Data Protection
The Company may, from time to time, review this Policy for compliance with the changing guidelines and relevant laws. In case of changes thereto, the Company will provide a public notification through appropriate channels
- 8. Contact channels
Enquires or questions on Personal Data Protection can be addressed via the following channels:
Montri Transport Corporation Public Company Limited
Address: 194/1 Serithai Road, Khwaeng Khannayao, Khet Khannayao, Bangkok 10230
Email: info@montri.co.th
Telephone: 0-2906-0160
Montri Transport Corporation Public Company Limited
Privacy Policy for Customer Version 1.1 (As of December 12, 2022)
Montri Transport Corporation Public Company Limited cares about the importance of information as well as the personal data rights of users. Therefore, we wish to inform you of our policies related to compiling data, collecting data, disclosing data, and maintaining data of stakeholders as follows:
- 1. Definitions
“You” means our stakeholders including customers, and visitors
“We” means Montri Transport Corporation Public Company Limited
“Business Partners” means persons or organizations who we have entered into agreement(s) to operate or administrate the use of the service, both currently and as developed or provided in the future.
“Personal Data” means the personal data of a person that can identify a person either directly or indirectly under personal data protection laws.
- 2. General Provisions
The personal data protection policy was created in order to set forth the details and methods of processing the personal data of users. You acknowledge that we may improve or amend our personal data protection policy as set forth herein as well as that which is specifically provided in any parts of our services and operations, in part or in full from time to time in order to coincide with the guidelines of usage of service and amended legal provisions. You can check the personal data protection policy at any time by sending the email: info@montri.co.th. Also, any changes to the personal data protection policy will be required by sending the email: info@montri.co.th and in the event that there is a material change, we will inform you through the appropriate channel.
In addition, this personal data protection policy will be used with the services that we offer both current and that are developed or provided in the future.
If you do not want to read all the details, the following information is what is important to you:
- At present, Montri Transport Corporation Public Company Limited is working with several companies or companies, as either data controllers or data processors.
- Your personal information may be processed within Montri Transport Corporation Public Company Limited in accordance with the law.
- We employ some third parties to process your information on our behalf. Some of them are not in Thailand.
- You have the rights over your personal information which may be limited in some cases depending on the applicable law. You can learn about how to exercise your rights later from the Thailand Data Protection Guidelines 3.0. (https://www.law.chula.ac.th/wp-content/uploads/2020/12/TDPG3.0-C5-20201208.pdf)
- 3. Data Collection
We collect data using various channels which allow us to operate per necessity. Your data which we store (“Personal Data”) is comprised of the following: name and family name, address, contact information, demographics, health information, medical records, product or service experience, and photographs or VDO recordings of associated activities. We may receive the data directly from you or the schools or persons that you previously provided explicit consent.
The above details are an example of the data we may collect. We will only collect your essential data for a period sufficient for the purpose of using your personal data as provided in Clause 4.
- 4. Use of Personal Data
We use your personal data for the following purposes:
1. To comply with legal requirements, including:
● To provide the services in an orderly manner in compliance with applicable laws, rules, and regulations as well as to comply with laws and regulations related to or governing us, including, but not limited to the Computer Crimes Act BE 2550 as currently in force and as amended in the future.
● Other related activities such as the children’s health information to comply with the Order of the Ministry of Education on the control of School Bus services BE 2562.
2. For lawful purposes as follows:
● To monitor and supervise your use to develop security standards of use of the service, procurement, and protection of the technology infrastructure by using your personal data as necessary as well as requiring encryption prior to use and/or a sample check, a test of use by another person to manage risk, catch, protect or prevent fraud or other activities that may be unlawful or contravene regulations of use or agreements.
● To improve the efficiency of the provision of service.
● Other related activities such as the registration of the school bus service and the bus service for field trips.
3. For the performance of a contract which you have entered into as a party with us or for complying with your request prior to entering into such contract.
● Other related activities such as the registration of the school bus service, the bus service for the field trips, and the creation of the student list and student activity records.
4. For other purposes as you have given your consent, regarding our business such as:
● Other related activity such as the commentary on the school bus service.
- 5. Disclosure of Personal Data to Third Party
We will not disclose your personal data to third parties that are unrelated to the activities involving you without your explicit consent.
In addition, we may be required to disclose your personal data in the following cases:
- As required by law, such as disclosure to government agencies, state agencies, agencies with duties to administrate the provision of service, agencies that oversee your activities and in the event there is a request to disclose the information under legal authority, such as for the purpose of court claims or legal proceedings or requests from private agencies or third parties related to the legal proceedings
- In the event of an organizational restructuring, merger, or liquidation, in which case we may disclose your personal data in part or in full that we have stored to the relevant company.
Your personal data that may disclose to the third party are as follows: name, family name, address, contact information, demographics, health information, medical records, product or service experience, and photographs or VDO recordings of associated activities. We may receive the data directly from you or the school or the person that you previously provided informed consent. The third party may include the GPS provider company.
In doing so, we will work to ensure that it is safe and that there is no effect on you.
We may be required to pass on personal data to foreign countries, including, but not limited to
- Cloud Storage, Google shared drive, and other shared storage drives
For these cases, we will pass on the Customer’ personal data only when these requirements have been met. These include:
- Receiving foreign country has substantial personal data regulation in place.
- Receiving organization has a substantial privacy policy in place and certified by the Personal Data Protection Committee (“PDPC”)
- Receiving organization is obligated to follow a substantial privacy policy with a sufficient remedial measure in accordance with the procedures identified by the Personal Data Committee (including, but not limited to, standard contract, vendor process agreement)
- A necessary task to exercise legal rights
- Consent has been received from appropriate individuals agreeing to the pass on of Personnel’s personal data to a foreign country that does not have a substantial privacy policy
- A necessary task to carry out contractual agreements of the Personnel
- A necessary task to carry out under a contractual agreement between two entities for the benefit of the Personnel
- To ensure the safety or limit further damage to an individual’s health who cannot give consent at the current time
- A necessary task for the good of the public
- 6. Legal Rights
You can inquire about your rights under the law as shown below:
- Right to be informed – you have the right to be informed of the details in the collection of personal data.
- Right of Access – you have the right to request a copy of all your personal data and assess if the company is processing your personal data in accordance with the law or not
- Right to Data Portability – for the case where a company has an automated platform allowing you to access your personal data automatically:
o You have the right to ask for your personal data to be transferred automatically to other organizations.
o You have the right to ask for your personal data to be directly transferred to other organizations, with the exception of cases where there is a technological limitation.
- Right to Object – you have the right to object to any data process activity of your personal data for the legal bases, including:
o Public Task or Legitimate Interest
o Direct Marketing Purposes
- Right to Erasure – you have the right to request data deletion or anonymization, in accordance to the following cases:
o Expiration of data processing required terms
o Consent has been withheld
o Objections raised on the data processing activity
o The processing activity is not in accordance with the law
- Right to restrict processing – you have the right to restrict any data processing activities, in accordance with the following cases:
o During the process of personal data assessment as requested
o For cases related to personal data which has initially asked for deletion and erasure but was followed by an additional request of processing restriction instead
o For cases when the data processing terms have passed, but you have requested for processing restriction due to legal reasons
o During the process of personal data processing objection verification
- Right to Rectification – you have the right to edit your personal data to be correct and concurrent to the present. If any mistake was detected, the company might not edit this themselves.
In some cases, due to its nature, we may not be able to proceed as you requested, such as when there is the necessity to carry out according to the contract or legal obligation. However, in the case where you had given consent to the processing of personal data, you may at any time withdraw such consent by contacting the related organization. We will then immediately cease to process your personal data when possible. Nevertheless, the withdrawal of consent does not withdraw the processing of personal data which has already been conducted.
Please be informed that we will record all activities related to your requests in order to solve the problems arise. For any queries regarding your personal data protection (you may study further regarding the Personal Data Protection (TDPG3.0) which is available at: https://www.law.chula.ac.th/event/9705/)
In the case where you intend to exercise your personal data protection rights, or any complain regarding the processing of personal data, please contact Ms. Pimmada Tawee-see-umnuay Tele. 02-906-0160 ext. 303 (Office hours GMT+7: 8 a.m. – 5 p.m.) or sending the email: info@montri.co.th. We will promptly proceed with your request as prescribed by the law. In addition, you are entitled to file a complaint regarding the incompliance with personal data protection to the Office of the Personal Data Protection Commission (‘PDPC’)
- 7. Security and Safety in Storing Personal Data
We have created and chosen to use a personal data storage system that has a mechanism and technics, including the organization policies and technical policies, that are appropriate with the risk opportunity and the severity of the possible damages, as well as the limitation of accessing your personal data from employees, staff and our representatives in order to protect your personal data from being accessed, amended or being unable to be used in an unlawful manner.
- 8. Contact Us
You can contact us regarding personal data protection if you have any questions or concerns about the personal data protection policy by contacting:
Name Ms. Pimmada Tawee-see-umnuay (Data Protection Officer: DPO)
Telephone (+66)2-906-0160 ext. 303 (Office hours GMT+7: 8 a.m. – 5 p.m.)
Email info@montri.co.th
Mail Montri Transport Corporation Public Company Limited
194/1, Serithai rd., Kannayao, Kannayao, Bangkok, 10230
- 1. Definitions
© 2024 Montri Transport Corporation Public Company Limited. All rights reserved.
