Privacy Notice for Using CCTV Cameras

1. Introduction

Bluebik Group Public Company Limited (hereinafter referred to as “Bluebik” or “we”) operates Closed-Circuit Television (CCTV) for surveillance within and around our buildings, facilities, and office premises (the “Premises”). This is done to protect life, health, and property. Through the use of this CCTV equipment, we collect personal data from employees, customers, contractors, visitors, or any individuals (hereinafter collectively referred to as “you”) who enter the Premises.

This CCTV Privacy Notice (the “Notice”) provides information regarding the collection, use, or disclosure of data that can identify you (“Personal Data”), as well as your rights, as follows:

2. Purposes for Collecting Your Personal Data

We collect your Personal Data for the following purposes:

1. To protect your personal health and safety, including your property.
2. To ensure the security of our buildings, facilities, and assets from damage, disruption, destruction, or other criminal acts.
3. To support relevant law enforcement agencies in deterring, preventing, investigating, and prosecuting legal cases.
4. To assist in dispute resolution processes that arise during disciplinary or grievance procedures.
5. To assist in investigation processes or procedures related to submitting complaints.
6. To assist in initiating or preventing civil litigation, including but not limited to legal proceedings in labor cases.
7. To comply with our other legal obligations where we deem the use of the CCTV system as a necessary measure to fulfill those obligations.

3. Methods and Categories of Personal Data We Collect and Use

We install CCTV cameras in visible locations within the Premises that we consider suitable for surveillance. This enables us to collect your Personal Data when you enter the Premises. Warning signs indicating CCTV usage are prominently displayed at entrances and exits.        Our CCTV system operates 24 hours a day and is monitored by our security personnel, except in cases of equipment, system malfunction and/or scheduled maintenance.

The categories of Personal Data collected are as follows:

–  Still images and video footage of you. –  Images of your property, such as vehicles, attire, etc.

Please note that we do not record audio and will not install CCTV cameras in areas that could unreasonably infringe upon your fundamental rights, such as restrooms.

4. Disclosure of Your Personal Data

We will keep CCTV footage related to you confidential and will not disclose your Personal Data collected through the CCTV system. Exceptions include disclosure to our affiliated companies or subsidiaries, or when necessary to achieve the purposes outlined in this Notice. We may also disclose CCTV data to authorized legal entities to assist in law enforcement, investigations, or various legal proceedings.

5. Your rights under the Personal Data Protection Act B.E. 2562 (2019)

If you believe your personal data has been recorded by our CCTV system, you may exercise the following legal rights:

	Rights of Data Subjects	Details
1	Right of Access	You have the right to access and obtain a copy of your Personal Data held by the Company, specifically data for which you have given consent, or to request disclosure of the acquisition of such Personal Data for which you have not given consent. We will provide you with a copy of such Personal Data within 30 days from the date we receive your request and/or as required by law. In some cases, we may request additional information to verify your identity and rights as part of our Personal Data security measures.
2	Right to Data Portability	You have the right to request that we transmit or transfer your Personal Data to another data controller by automated means, and you have the right to directly receive Personal Data that we have transmitted or transferred to another data controller, unless it is technically unfeasible.
3	Right to Object	You have the right to object to the collection, use or disclosure of personal data at any time, for instance, in cases related to direct marketing purposes.
4	Right to Erasure	You have the right to request the erasure or destruction of your Personal Data for which you have given consent, or to have your Personal Data anonymized so that you cannot be identified. This right applies in the following cases: When the Personal Data is no longer necessary for the purposes for which it was collected, used, or disclosed. When you withdraw your consent for the collection, use, or disclosure of your Personal Data and we have no legal grounds to continue collecting, using, or disclosing it. When you object to the collection, use, or disclosure of your Personal Data, and we have no legal grounds to refuse your request. When the collection, use, or disclosure of Personal Data is unlawful under the Personal Data Protection Act.
5	Right to Restrict Processing	You have the right to request the suspension of use of your Personal Data in the following cases: While we are in the process of verifying whether your Personal Data is accurate, current, or complete. When your Personal Data should be erased or destroyed, but you request its suspension instead. When your Personal Data has been unlawfully collected, used, or disclosed, but you request its suspension instead. When your Personal Data is no longer necessary for the purpose for which it was collected, but you need us to retain it for the establishment, exercise, or defense of legal claims. When we are in the process of proving our right to reject your objection to the collection, use, or disclosure of Personal Data.
6	Right to Withdraw Consent	If you’ve given us your consent to process your Personal Data, you have the right to withdraw that consent at any time. This right applies unless the withdrawal is restricted by law or by a contract that benefits you. Please note that withdrawing your consent won’t affect the lawfulness of any Personal Data processing we did based on your consent before you withdrew it.
7	Right to Rectification	We are obligated to ensure that such Personal Data is accurate, current, complete, and not misleading.
8	Right to File a Complaint with the Expert Committee	You have the right to lodge a complaint if we, or our data processor, including our employees or contractors, violate or fail to comply with the Personal Data Protection Act or any notifications issued thereunder.

You can exercise your rights as a data subject by contacting our Data Protection Officer, using the details provided at the end of this Notice. We will inform you of the outcome of your request within 30 days from the date we receive your request, submitted via our designated form or method. If we deny your request, we will notify you of the reasons for the denial through the contact channel you provided.

6. Personal Data Retention Period

In general, we will retain CCTV Personal Data for a period of 30 days from the date of recording. After this period, the data will be automatically deleted.

However, we may retain CCTV Personal Data for a longer period if there are reasonable grounds to do so. Examples include retention until the conclusion of relevant disciplinary or legal proceedings, where specific data retention periods are mandated by law, or when certain CCTV system data must be preserved for handling specific incidents or in response to a legal claim from any individual exercising their legal rights.

7. Personal Data Security Measures

We implement appropriate technical and organizational security measures to protect your Personal Data. These measures are designed to prevent loss, unauthorized access, deletion, destruction, use, alteration, modification, or disclosure of Personal Data.

We will review and update our security measures periodically as needed, or when relevant technology evolves. This ensures that our security measures remain effective, appropriate, and compliant with the minimum legal requirements set forth by relevant government authorities.

8. Changes to This Privacy Notice

We may amend or update this Notice as we deem appropriate. Any changes will be communicated to you via our website, www.bluebik.com, with the latest version date indicated at the end for your reference. If there are instances where the collection, use, or disclosure of Personal Data differs from the purposes previously notified, we will provide you with additional notice.

9. Contact Information

You can contact us regarding this Notice or exercise your rights under this Notice via the following channels:

• Bluebik Group Public Company Limited
• Address: 51 Naradhiwas Rajanagarindra Road, Silom, Bangrak, Bangkok
• Phone: (+66) 2-636-7011 (Monday – Friday, 9:30 AM – 6:30 PM)
• Email: [email protected]

Last updated and announced on May 27, 2022.