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Privacy Notice for Business Partners in accordance with Thai law

In the following, NIPPON STEEL ENGINEERING CO., LTD. ("NSE"), its Head Office located at Osaki Center Building, 1-5-1 Osaki, Shinagawa-ku, Tokyo 141-8604 Japan, provides information on the collection, use or disclosure ("processing") of personal data in connection with its relationship with existing and potential customers, trading companies, end users, goods and service suppliers, agents, advisors, outside auditors, research institutions, industrial organizations and other persons with whom NSE or any of its group company maintains or is considering to create a business relationship (each a "Business Partner") pursuant to Article 23 of Thailand's Personal Data Protection Act ("Act") to the extent the Act applies.

A. Categories of personal data

In the context of NSE's business relationship with a Business Partner, NSE may process the following personal data:

  • Profile and contact information, such as full name, work position, work address, work telephone number, work mobile phone number, work fax number and work email address of a Business Partner who is an individual, or a person working for a Business Partner (each shall be referred to as a "Business Partner Contact"); and
  • Further information, including sensitive data such as personal medical information, processed in connection with the relationship between NSE and a Business Partner or voluntarily provided by a Business Partner Contact.

B. Intended purposes of processing and legal basis for processing

NSE processes the personal data indicated above in section A for the following purposes:

  • Communicating with Business Partner Contacts about products and services of NSE, e.g. by responding to inquiries or requests, entering into or executing transactions for products or services, providing technical support;
  • Communicating with Business Partner Contacts about the products and services of Business Partners;
  • Planning, performing and managing the business relationship with Business Partners;
  • Solving disputes, enforcing agreements and/or to establish, exercise or defend legal claims;
  • Complying with applicable laws and regulations, including cooperating with relevant authorities and regulators.

Where personal data is explicitly provided by Business Partners Contacts, the legal basis for the processing is the consent given by the Business Partner Contact (Articles 19 and 24 of the Act).

Where processing of personal data is necessary for the performance of a contract to which a Business Partner Contact is a party or in order to take steps at the request of a Business Partner Contact prior to entering into a contract, the legal basis for such processing is Article 24(3) of the Act.

Where NSE processes personal data to comply with a law to which it is subject, the legal basis for the processing is Article 24(6) of the Act.

Otherwise, the legal basis for processing of personal data indicated above in section A by NSE is Article 24(5) of the Act. The legitimate interests pursued by NSE is the transmission and receipt of information in order to conduct its business activities, including expanding and/building a business relationship with Business Partners.

NSE generally does not seek to collect or otherwise process special categories of personal data of Business Partner Contacts, such as those revealing religious or philosophical beliefs, in the ordinary course of business. Where it becomes necessary to process such special categories of personal data for any reason, NSE relies on the following legal basis depending on the circumstances: (i) explicit consent of the Business Partner Contact has been given (Article 26 of the Act); (ii) the personal data is disclosed to the public with the explicit consent of the Business Partner Contact (Article 26(3) of the Act); or (iii) processing is necessary for the establishment of, compliance with, exercise of or defense of legal claims (Article 26(4) of the Act).

C. Disclosure of personal data

For the purposes of processing indicated in section B above, NSE may disclose personal data to the following recipients or categories of recipients:

  • Directors, officers, employees and auditors and any persons who correspond to such positions ("Staff") of NSe;
  • External advisors such as attorneys, accountants and tax advisors ("Advisors") of NSE;
  • Group companies of NSE and their Staff and Advisors with whom NSE needs to share the data with for the purpose of processing;
  • Other Business Partners and their Staff and Advisors with whom NSE needs to share the data with for the purpose of processing;
  • Governmental agencies, boards, commissions, officers, officials or entities exercising legislative, judicial, regulatory or administrative functions;

Recipients of personal data may be located in countries and areas outside of Thailand ("Third Countries"). NSE transfers personal data to external recipients in Third Countries only in the case where: (i) the respective recipient is located in a country or area which has adequate data protection standard; (ii) the Business Partner Contact explicitly consents to the transfer of his/her personal data, or (iii) the exemption under Article 28 of the Act applies.

D. Period for which personal data will be stored

Unless indicated otherwise, NSE will retain personal data for as long as is necessary for the purpose for which they were collected or otherwise processed (including as required by applicable law or regulation or for the exercise or defense of legal claims).

E. Rights of the data subject

  • Right to withdraw consent

    Where the processing is based on his/her consent (Article 19 of the Act), a Business Partner Contact has the right to withdraw consent at any time, without affecting the processing of personal data which the Business Partner Contact has already given consent legally.

  • Access, data portability, erasure, restriction, complaint

    With regard to the processing of his/her personal data, a Business Partner Contact has the following rights within the limits set forth in the Act:

    • Right to request NSE for access to and obtaining a copy of his/her personal data, or request NSE to disclose the means by which NSE obtained the personal data without the Business Partner Contact's consent, pursuant to Article 30 paragraph 1 of the Act;
    • Right to receive (or request to send to a third party, if it can be done by automatic means) his/her personal data from NSE in format which is readable or commonly used by ways of automatic tools or equipment and can be used or disclosed by automated means, or right to request to directly obtain his/her personal data in such format NSE sends or transfers to a third party, if this is technically possible, pursuant to Article 31 paragraph 1 of the Act;
    • Right to request NSE to erase, destroy or anonymize his/her personal data, pursuant to Article 33 paragraph 1 of the Act; and
    • Right to file a complaint to the Personal Data Protection Committee in the event NSE or its Data Processor (as defined in Article 6 of the Act) including their employees or contractors violates or does not comply with the Act or notifications issued in accordance with the Act, pursuant to Article 73 paragraph 1 of the Act.
  • Right to object

    Pursuant to Article 32(1) of the Act, a Business Partner Contact has the right to object at any time the processing of his/personal data which is collected based on Article 24(5) of the Act (see section B above), unless NSE (i) demonstrates that there is compelling legitimate ground for the processing of such personal information, or (ii) proves that the processing is carried out for the establishment of, compliance with or exercise of legal claims, or defense of legal claims.

    If personal data is processed for direct marketing purposes, or for the purpose of scientific, historical or statistic research, unless it is necessary for performance by NSE of a task carried out for reasons of public interest, a Business Partner Contact has the right to object at any time to the processing of his/her personal data for such marketing, also pursuant to Article 32(2) and (3) of the Act.

  • Right to restrict usage and ensure accuracy of personal data

    A Business Partner Contact may request that NSE restrict the use of his/her personal data under circumstances, pursuant to Article 34 paragraph 1 of the Act.

    A Business Partner Contact may request that NSE ensure his/her personal data remains accurate, up-to-date, complete, and not misleading, pursuant to Article 35 of the Act. If NSE does not take action concerning such request, it must record such request of the Business Partner Contact together with reasons.

F. Data Privacy Contact

If a Business Partner Contact has questions with regard to processing of his/her personal data or wants to exercise any of the above rights in section E above, he/she may contact NSE at: nsengi_EEA_rep@eng.nipponsteel.com

As of: 06.01.2022

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