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Privacy Notice for Suppliers, Business Partners, Tenant and/or Lessor

CP Axtra Public Company Limited (herein referred to “Company” or “We”) has an intention to keep and protect personal data of suppliers, business partners, tenant or lessors, vendors, contract partners, service providers, sellers including their representatives (collectively called “You”, “Partners” or “Data Subject”) in accordance with Personal Data Protection Act B.E. 2562. This Privacy Notice determines method to collect, use, disclose and manage your personal data (collectively called “Process”), which the Company has collected from our business operation including any transactions or agreements of products supply or sales or any business agreements with you.

Personal data means any information relating to a person, which enables the identification of such person, whether directly or indirectly, such as name-surname, address, email, telephone no., identification no. and login registration i.e. username and password including all personal data provided by you when using our service (such as name, username, social media account and line ID), transaction data and other relevant data etc. However, data of juristic person is excluded.

Subject to this policy, groups or types of persons which we collect and process data include as follows:

  1. Potential Partners means any person which may be engaged as the Company’s Partners, including business partners, sellers, suppliers and/or vendors, agriculturist, Small and Medium Enterprise (SMEs), contract partners, service provider, and tenant or lessor in the Company’s places or stores having intention to enter into the agreement with the Company and/or register as the Company’s Partners.o the agreement with the Company and/or register as the Company’s Partners.

  2. Partners means business partners, sellers, suppliers and/or vendors, agriculturist, Small and Medium Enterprise (SMEs), contract partners, service provider, and tenant or lessor in the Company’s places or stores including any other person entering into bidding for providing products and/or services to the Company, any other person registered as the Company’s Partners or having similar relationship as aforementioned with the Company such as being a consultant, professional, specialist, lecturer, business project participants, contract partners or other persons having similar relationship.

  3. Any persons related to the Potential Partners or Partners means an individual which relates to or is the representative of the Potential Partners or Partners such as director, employee, agent or staff of the Potential Partners or Partners, which is the juristic person, including any persons whose personal data appearing on the documents used for relevant process such as manager, purchaser/buyer, receiver, check payer, etc.

The Company is the Data Controller of your personal data.
The Company has intention to take care of, collect, use, disclose and protect your personal data legally, so the Company had prepared this privacy notice (“Privacy Notice”) to:

  • classify types of personal data which the Company collects;
  • explain purpose of use and/or disclose of personal data which the Company has collected;
  • explain that the Company may disclose your personal data to the Company’s affiliates and Charoen Pokphand Group (“Group Company”) and other companies in any cases;
  • explain your right and how to exercise your right relevant to personal data; and
  • other relevant issues related to personal data management.

This Privacy Notice may be updated from time to time which the updated version will be announced on our website or other appropriate channel. Please study the latest Privacy Notice (subject to any amendment) in order to understand how we manage your personal data including your rights in case that your personal data is collected, used and disclosed by the Company.

Your personal data such as name-surname, occupation, identification no., passport no., date of birth, tax no. (if any), etc.
Your contact data such as address, email address, telephone no., Line ID and contact person, etc.
Your account data including your registered data to log in Lotus’s Supplier Toolkit or other Company’s similar system such as username, password and supplier code etc.
Your transaction data related to sales, service and rental such as supplier code, tenant code, product or service details, delivery details, bank account no., and amount, etc.
Supporting documents for supplier registration or engaging in any transaction such as personal data appearing on the copy of identification card, tax no., copy of passport, copy of certificate of name-surname change, copy of household registration, copy of driver license, car plate no., type of car, copy of land title deed, copy of power of attorney, copy of company affidavit, copy of tax registration, invoice, receipt, cash bill, substitute documents of receipt, check and check stub, payment voucher, copy of book bank, money transfer receipt, record of approval for direct credit registration, copy of any professional certification, etc.
Technical data such as computer traffic data (Log), computer IP address, and information collected by Cookies or other similar technology, etc.
• Other data which the system may ask for or you provide for registration to log in Lotus’s Supplier Toolkit or other similar system, voice recording, video recording of the meeting through online application such as Microsoft Teams, Zoom, image record and video recording through equipment, etc.

The Company collect your personal data from many sources as follows:

Your personal data which you provide to the Company such as when you fill in any form on website or other channels, when you enter into any agreement with the Company, when you send documents and their copies containing personal data to the Company, or when you query, give opinions or feedback or send complaints to the Company via telephone, email, fax, post or application, etc. i.e. name-surname, occupation, identification no., passport no., date of birth, tax id. (if any) including contact information i.e. address, email address and telephone no., etc.
Website or Online Platform such as user account including your information used for registration to log in Lotus’s Supplier Toolkit or other similar system of the Company i.e. username, password, supplier code, name-surname, address, email address, telephone no., etc., conducting survey or filling in any form to receive information or connect with the Company.
Offline communication such as your personal information that has been provided when you enter into the Company’s premise, contact us via phone call or provide name card.
Personal data which the Company receive from third party such as your personal data collected from public sources, your business or commercial resources, etc.

The Company uses your collected personal data for purposes set out below.

To collect name list of Potential Partners or other relevant persons for the Company’s procurement
  • Contract basis: In case that the Potential Partners wish to enter into sales agreement or service agreement with the Company and have filed an application or provided their personal data to the Company themselves.
To register Partner or other relevant persons  
  • Contract basis: Personal data processing is necessary for proceeding a request made by the Potential Partner including other persons having similar relationship in order to be registered as Partners or other similar proceeding.
To prepare report and analyze data which is essential to the Company’s business 
  • Legitimate Interest basis: Personal data processing is necessary for legitimate interest to operate the Company’s business such as to prepare products/services ordering report, purchase order and transaction history record, etc.
To purchase or select suppliers or other similar persons
  • Contract basis: Personal data processing is necessary for proceeding bidding request from Partners or similar persons prior entering into the sales agreement, service agreement, lease agreement or other business agreement or others relating to the Company’s procurement.
  • Legitimate Interest basis: Personal data processing is necessary for legitimate interest to operate business and comply with the Company’s Procurement Policy such as verification of Partner’s data and qualification.
To register new Partners or other similar persons including to proceed request from Partners or other similar persons
  • Contract basis: Personal data processing is necessary for registration of new Partners or other similar persons including to proceed, in the Company’s system, a request from Partners or other similar persons such as amendment of Partner’s data.
To prepare and manage agreements between the Company and its contractual parties
  • Contract basis: Personal data processing is necessary for proceeding a request made by a contractual party which expressing his intention to enter into an agreement with the Company.
  • Legitimate Interest basis: Processing of a contractual party’s (or other relevant person or representative of such contractual party in case that such party is juristic person) is necessary for legitimate interest to prepare and manage the Company’s agreement such as verification of identity and qualification.
To perform obligations under agreement
  • Contract basis: Personal data processing is necessary for performing obligations under the agreement made by the Company and you or other similar persons such as making purchase order of products or services, invoice and payment including receipt of products or services.
To manage and improve the Company’s business operation
  • Legitimate Interest basis: In order to improve information technology system, communication means and business operation, the Company requires personal data for research and development of information technology system (including information security system) and business operation.
To conduct Partner (or other similar person) satisfaction survey
  • Legitimate Interest basis: Company may, from time to time, ask your support to conduct survey or evaluate the operation run by the Company or other matters assigned by the Company. In case that you agree to participate in such survey, it would be deemed that you consent us for collecting, using and disclosing your personal data as additionally provided. In addition, your personal data processing will be in line with the purposes set out in this Privacy Notice or other purposes set out in each survey.
To set up activities or campaigns for PR, advertising and marketing including Corporate Social Responsibilities (CSR) events
  • Contract basis: Personal data processing is necessary for performing obligations under the agreement made by the Company and you or other similar persons such as to publicise the photo of you in order to promote the Company’s activity.
  • Legitimate Interest basis: When you participate in our marketing, advertising and PR, CSR activities or any other campaigns arranged by us including a live streaming or video recording for the above purposes, whether at our stores or other premises, we may use your photograph, footage or photo in order to publish in our online, print and social medias where we will notify you earlier via appropriate means subject to each circumstance.
To contact and communicate with you
  • Legitimate Interest basis: The Company needs to use your personal data to contact about the Company’s news, or to provide information or assistance as appropriate.
To exercise legal rights
  • Legal Obligation and Legitimate Interest basis: Personal data processing is necessary to defend or settle legal disputes between the Company and you in case of any dispute or breach of agreement.
To monitor the safety and security of the individual and Company’s asset
  • Legitimate Interest basis: Personal data processing is necessary for legitimate interest to oversee and monitor the safety and security of Company’s asset such as CCTV usage to prevent loss or damage to the Company’s assets or to track back assets or to claim damages in case of any loss or damage to the Company’s assets.
  • Vital Interest basis: Personal data processing is necessary for verifying, monitoring, protecting or suppressing any incidents which may be harmful to a person’s life, body or health.
To proceed others as necessary and beneficial to you or directly relating to the above purposes
  • Legitimate Interest basis: Personal data processing is necessary for legitimate interest to proceed what is essential to the Company and/or beneficial to you or directly relating to the above purposes.

The Company may process your personal data for other purposes apart from what mentioned above subject to your consent or in case it is allowed under the law i.e. for (a) compliance with a law (b) preventing or suppressing a danger to a person’s life, body or health; (c) performance of a task carried out in the public interest or compliance with orders of competent official; (d) legitimate interests of the Company, except where such interests are overridden by your the fundamental rights.

**In addition, the Company has no purpose to collect your sensitive data such as race, ethnic, religion, and health data. In case that you submit any documents containing sensitive data i.e. copy of identification with religion and blood type information, please cover/strike out such sensitive data before submission. **

You as the data subject can exercise your right relevant to your personal data under Personal Data Protection law as follows:

• Right to withdraw consent for processing your personal data under consent basis: In case that the Company process your personal data by referring to your consent, you are entitled to withdraw your consent to process your personal data provided to the Company. However, if you withdraw consent, you may not be eligible for some benefits or may not be able to join some activities or projects or other similar purposes.
• Right to access and receive of your personal data which the Company collects, uses and discloses: You are entitled to access and request for a copy of your personal data processed by the Company under Personal Data Protection law.
• Right to transfer your personal data: Subject to the technical system and Personal Data Protection law, you are entitled to transfer your personal data to other data controller or yourself in form which is readable or accessible by automatic devices or tools unless it is not applicable.
• Right to object to process your personal data: You are entitled to object to process your personal data as defined by Personal Data Protect law if your right is more important than the Company’s benefit. However, the Company may not be performed accordingly if the process is required for legal proceedings or claims.
• Right to delete your personal data: You can request the Company to delete, destroy or de-identify as defined under Personal Data Protection law. In addition, we may collect your personal data for compliance with the law and relevant regulations and permitted purposes. Therefore, your personal data may not be deleted as requested.
• Right to suspend to process your personal data: You may request the Company to restrict or suspend to process your personal data instead of deleting it as defined by Personal Data Protection law.
• Right to modify your personal data to be up-to-date: You are entitled to amend your personal data if your personal data is incorrect, outdated, incomplete or wrong.

However, subject to the law and relevant regulations, the Company may reject or partly perform as your request. For example, the Company may restrict right to access your personal data if it affects to other’s right and freedom, or in case that you request to delete your personal data, the Company may be required to keep that data for exercising our legal right or obligation.

When you have been registered as Partners (partners, tenant, suppliers or else), the Company may disclose your personal data within Group, business partners, service providers and data processors assigned or hired by the Company to manage/process your personal data on behalf of the Company in order to provide service. In addition, it can help to collect, use and disclose your personal data to be in line with purposes set out in this Privacy Notice including disclosing personal data under the law or authorized government sector such as Trade Competition Commission Thailand (TCCT) or for justice or for legal claim or counterclaim.

The Company is aware of the importance to protect and manage your personal data, therefore, the Company has set up rules, procedures and guidelines on information security in order to protect your personal data suitably.

The Company will not keep your personal data longer than we need to by considering of the following factors:
• Why we collected it in the first place;
• How old it is;
• Whether there is a legal/regulatory reason for us to keep it;
• Whether we need it to protect you or us.

The Company will retain your personal data as necessary to achieve the defined purpose of process personal data. The retention period may be changed depending on the purpose of process personal data, the prescription under the law (if any) and the Company’s guideline.

The Company will retain your personal data not exceeding 10 years counting from the last transaction date between you and the Company. The Company may retain your personal data longer than that if the law allows or it is necessary for legal claim.

The Company would like to have a chance to resolve any complaints you have, however, you also have the right to complain to the Office of the Personal Data Protection Commission about how we have used your personal data.

If you have any questions about how we collect, store and use personal data, please email to [email protected] or if you are SMEs, please email to [email protected]

Our Data Protection Officer can be contacted at
Email: [email protected]

This Privacy Policy was latest updated on 30 May 2023.







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