Thailand Insurance Institute
Thailand Insurance Institute (the “Company”) as the owner and the administrator of the design and training course, both online and offline that may be hosted at the Company’s premises or at the relevant customer’s venue (the “Trainings”), would like to inform you that once you enroll to the Training with the Company, you will be considered being the user of the Company and during the Training delivered by the Company, the Company would need to process the personal identifiable information (the “PIIs”) of the users. Therefore, the Company intend to announce this Privacy Policy to define the rights and obligations as well as all the conditions that relates to the collection, composition, use and transfer of the PIIs that the Company may undertake for the user’s information.
This Privacy Policy shall be applicable to Training of the Company only and shall not be applicable to the training or other services of any third party that the Company does not have any control over. In such circumstance, you should be studying the relevant privacy policy declared and announced by those third parties that are separate from this Privacy Policy.
If you do not agree to the PIIs process defined by the Company under this Privacy Policy or the amendment thereof, the Company reserves the right to refuse to provide any access to the user to enter into the Training since the PIIs processing as defined hereunder are critical for the provision of the Training to you. As long as the user remains enrolling and participating in the Training, it shall be deemed that the User accepts this Privacy Policy at all times.
The Company may adjust or amend this Privacy Policy at any time in order to assure the compliance with the relevant laws and regulations and to match with the Trainings provided by the Company; provided that the Company shall notify you of all the amendment and modification made by announcing the amended Privacy Policy on Company’s website.
PII that the Company is processing in the Training
In the provision of the Training, the Company needs to collect, compose and process PIIs of the user where the Company may get this information directly from the user or may receive the PIIs from other third party, including the affiliates or the other employer company that submit the PII of their employee for the training purpose. In case of the third-party sources, the Company shall deem that relevant user who is the data subject has given consent to such disclosing party already. The PIIs that the Company will process include the following information of the user:
- General Information about you, including name, surname, age, date of birth, identification card (for the purpose of the preparation of Labor Skill Development Department-endorsed curriculum);
- Contact information, including address, contact address, telephone number, email and the work address;
- Payment information, including payment details, credit card information and bank account;
- Training information, including the training logs and the online identifier for the online access to the online Training, i.e. username and password;
- Other technical information that can identify or link to your identity, including IP address, setting and browser connection that the user uses to connect to Training website and may include various types of cookies used in order to track your behavior on the Training website;
- Facial image of you that participate in the Training that may include the atmospheric image during the Training or the group photos after the completion of the Training;
- Within the area of the offline Training premises, the Company has installed CCTV system that during the process of CCTV operation, certain facial image of you entering the premises will be collected.
Objectives for the PII Process Undertaken by the Company
- The Company shall collect, compose and use the PIIs of the user for the obligations performance relating to the Trainings to the user, including (i) verifying the identity and qualification of the user by cross-checking the information submitted in paper or online; (ii) verifying the payment conditions; (iii) since the condition for the Training completion for certain course relies on the fact that the user shall achieve certain percentage of the time attendance, monitoring the attendance of the user in the Training with the photo taken as the evidence; and (iv) contacting you to communicate with the user during the Training attendance.
- The Company shall collect any facial image of any person that enters into the premises of the Company through CCTV operation for the security and safety purpose of the premises and nay person entering the premises that include without limitation the training participants; provided that the image stored in the system will be collected for 90 days;
- As the Training service provider under the license of the Labor Skill Development Department, for certain curriculum, therefore, the Company shall collect the PIIs of the Training participant in order to fill in the application form and registrar of the trainer as instructed and obliged under the applicable laws;
- The Company may collect and use the PIIs of the user to analyze the interest of the user for the improvement of curriculum and training course that would match with the interest of the user the most;
- The Company shall collect and use your PII for the collection of feedback after Trainings, including information enquiry or satisfactory feedback after the Training or submission of any other request;
- The Company shall collect the user’s PII for the performance of legal obligations pursuant of the relevant laws and regulations, including in particular the preparation of withholding taxes invoices;
- Upon receipt your consent, the Company shall use the PIIs for contact to give advice and recommendation on any Training course that you may be interested; provided that you can withdraw consent any time as defined under the applicable laws;
- The Company may collect the statistic information of the users attended the Training; provide that the Company may process such information on the anonymized basis.
All of your PII, except for the PII collected by the CCTV system that have the definite retention period as defined, shall be stored throughout the Training period and after the completion of each Training that the Company may have any necessity to store those information for the purpose of facilitating in the subsequent training of you and in order to protect the legitimate rights to object that the Company may have against or with you. In addition, if the PII processes are required under the applicable laws (i.e. the Labor Skill Development Department) or the tax purposes, the Company shall keep the revenant information for the period of time as instructed in the relevant laws.
Disclosure of the PII
For the purpose of the provision of the Training pursuant to the terms defined, the Company may need to disclose the PIIs of the Training participants in the following circumstances:
- To disclose to the Company’s affiliate or the employment company of the Training participant in order to verification of your PIIs and the qualification of the relevant Training participants pursuant to the terms and conditions defined. Also, in case the employment company pays for the Training attendance, the information and facial photo of the Training participants shall be shared with the relevant employment company pursuant to the service agreement entered into between the Company and the employment company;
- To disclose to the third-service provider that the Company engages to support, manage and facilitate in the Training provision and performance or the Company’s website, including without limitation the counsel, third-party outsourced service providers (i.e. third party service providers providing the website performance – Google analytics and the cloud service provider that may be located in Thailand or abroad); provide that the disclosure and share shall only be executed for the specific purposes defined and shall only be disclosed on the need-to-know basis where the assurance measures shall be put in place that the recipient of the information shall implement the relevant information security measures of the PIIs being disclosed;
- To disclose to the governmental authorities that the Company is obliged to disclose and submit the relevant reports relating to the Training to, including for instance the Labor Skill Development Department and the Revenue Department;
- To disclose for the purpose of protecting the Company’s legitimate rights or any rights relating to the Company’s assets; detecting and investigating any violation of the terms and conditions for the services provided by the Company; provided that such disclosure shall be done on the limited and specific purposes as defined.
- In case that the Company is obliged under the applicable laws, court judgment or administrative order to disclose any PII of any particular users, the Company would need to do so only on the necessary basis.
- Upon receipt of your consent, to disclose or share your PIIs to any third party that you have given the explicit consent for such disclosure or share; provided that you shall be entitled to withdraw such consent at any time.
Representation on the Appropriate Information Security of the PII
The Company represents and guarantees that the Company shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of the PII in any form or in any circumstance by either internal or external persons and the Company commits to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws.
Data Subject Rights
The Company acknowledges and accepts the User’s rights as the data subject over
Contact Us:
Name : T.I.I. Co., Ltd. (Insurance Institute)
Telephone :
Email : dpo@tiins.com