Privacy Policy - ImagineHealth

Privacy Notice for Website

ImagineHealth Company Limited (referred to as “Company”, “Imagine”, “we” or “our”) is the medical travel facilitator and medical travel accreditation service provider that is always committed to conduct its business under good corporate governances, including recognizing the importance of data security and privacy where we intend to process your personal data with transparency.

We are a website which conducts services to facilitate website visitors and our clients. This privacy notice (the “Notice”) will cover the following website: www.imaginehealth.io (hereinafter referred to as the “Website”).

We are deeply aware of the importance of protecting personal data and right to privacy of yours as you are the user of the Website, (hereinafter referred to as “User” or “you”). We, as the data controller under the Personal Data Protection Act B.E. 2562 (A.D. 2019) (“PDPA”), we therefore announce this Privacy Notice (the “Notice“) to inform you of the protection of your personal data that is collected, used, disclosed and/or transferred (“process” or “processing”) to any other relevant persons by the Company.

We ensure that your personal data will be secured by a stringent security standard throughout the processing procedure. We will not process your personal data for purposes other than those specified in this Notice unless you consent thereto.

1. Definitions

“Personal Data” refers to any information that identifies or can be used to identify you, which is collected by the Company as specified in this Notice.

“Sensitive Data” refers to Personal Data classified as sensitive data under the Personal PDPA that the Company is permitted to collect, use, disclose and/or transfer with your explicit consent, e.g., the information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, a natural person’s sexual orientation or criminal record, or data concerning health, disabilities, trade union membership, genetic data, biometric data, and other data that affect the Data Subject in the same manner.

2. Personal Data Collected, Used and/or Disclosed by the Company

We will collect, use, and/or disclose your Personal Data which includes, but is not limited to, the following:

2.1 General Personal Data

Personal information, e.g., title, first name, middle name, last name, date of birth, gender, nationality, photograph, country of residence, national ID card number, and passport number.
Contact information, e.g., address, mobile phone number, home phone number, and email address.
Financial information, e.g., bank account, credit or debit card information.
Information relating to patient treatments which may include Sensitive Data, e.g., health data, diagnosis, data about illnesses to be consulted, disabilities, medication, drug allergy, health-related reports, laboratory test results, and diagnoses, photos, and videos.

2.2 Automatically Collected Data

We may automatically collect information about your use of service, e.g., access time, device ID, or other unique identifiers, IP address, mac address, overall usage data, usage history, settings, language information, device name and model, location and time zone, network provider, operating system information, and session length.

3. Source of Your Personal Data

We will receive your Personal Data from the main channels as follows:

3.1 From the Personal Data you voluntarily release to us to request our services, whether through filling out a service request form at the office, contacting via social media accounts, chat, phone calls, or other forms filled out through the Company’s Website such as appointment forms, inquiry forms, product purchase or service request forms, and news subscription forms; and

3.2 We may receive your Personal Data from other sources, e.g., your family members, intimate persons, or any other third party assigned by you to register and complete your service request form. We may also receive your Personal Data from the facilitators, travel agencies, representatives, or alliances that refer or introduce you to receive our services.

4. Purposes and Legal Bases

4.1 We will process your Personal Data based on legal bases as provided below:

We rely on contractual obligations to process your Personal Data, for instance:
- register new clients into the Company’s or Temos’ information system;
- proceed with the registration of service with the Company through online platforms such as Booking an Appointment, Pre-registration, Telemedicine;
- assist you in buying products and services from the Company through online platforms such as accreditations and medical treatment programs;
- collect payment for products and services, e.g., service packages, purchased products, etc. through the Website;
- estimate the cost of accreditations or medical treatments and the service fee for consulting with a doctor; and
- facilitate the processing of treatment reservations in the network of partner treatment providers.

4.2 We rely on legal obligations to process your Personal Data, for instance:

comply with the applicable laws to achieve the objectives relating to medical diagnosis, health services, medical treatment, compliance with professional ethics, health management, insurance proceedings, and welfare with regard to medical treatment for those who are legally entitled;
submit Personal Data to government agencies as required by law;
comply with court orders or orders of competent authorities as required by law;
pay legal fees; and
establish and exercise legal claim as permitted by law.

4.3 We rely on legitimate interest to process your Personal Data, for instance:

facilitate your access to the Website;
manage bookings and appointments for medical treatments or consulting by a doctor;
contact you for services of Telemedicine, Tele-Consultation with Doctor, via channels specified by the Company;
provide assistance, answer questions, respond to inquiries, and accept the request with regard to services;
contact you due to your complaint or comments on the Company’s services that you want to improve;
track your use of services to improve the quality of the Company’s services;
develop and improve service quality, increase service efficiency, and facilitate the use of services through the Company’s systems to the User and customers;
disclose your Personal Data, where it is necessary, to investigate, prevent, or act in reprisal in the event of suspected illegality or fraud, or to safeguard the safety, rights, or property of the Company or of another person; and
disclose your Personal Data for the purpose of internal auditing.

4.4 In the event that you have given your explicit consent, we will collect, use, disclose and/or transfer your Personal Data for the purposes set forth in each of the following consent:

Delivery of news, advertisements, notifications, benefits and promotions of products and services, beneficial campaigns or invitations to the Company’s activities via all communication channels that you have provided to the Company.

Disclosure of Your Personal Data

We will not disclose your Personal Data for purpose other than purposes specified herein, unless having been consented to do so.

The Personal Data that you have provided to us may be transferred outside Thailand and disclosed to our international agents or partners that you have contacted for our services. We will endeavor to ensure that your right to privacy is protected by security protection measures of our standard.

We may disclose your Personal Data to our affiliates, vendors, business partners, or third parties, e.g., insurance companies, financial institutions, primary doctors, medical professionals, medical specialists, and/or medical practitioners, medical technology clinic, manufacturers or distributors of medicines and medical supplies, embassy, person who handle international travel, customer service provider, marketing, advertising and communication service providers, information system providers, cloud service provider, nearby hotels that are alliance with us, transport service providers, document storage service providers, debt collection service providers, accounting and legal consultants, external auditors, internal auditors, financial auditors, and your family, relatives, intimate persons, agencies or employers. We may proceed any other actions to complete the purposes specified in this Notice in order to benefit our services.

We will endeavor to ensure that these individuals and organizations will process your Personal Data strictly in accordance with this Notice and as permitted by law.

Where it is necessary to disclose your Personal Data in order to comply with the law, court orders, or orders of any governmental or regulatory agency such as the Embassy and Immigration Office, or to relevant agencies in order to verify your Personal Data to prevent fraud or corruption, we reserve the right to do so without your prior consent.

6. Collection of Personal Data of Minors, Incompetent Persons, and Quasi-Incompetent Persons

In the event that we must process the Personal Data of minors, incompetent persons, or quasi-incompetent persons, we shall have their parents, legal representative, guardian, or curator, as the case may be, consented on behalf of them.

If a minor or a quasi-incompetent person is legally permitted to give consent on their own behalf, we shall require combined consent from them and their legal representative.

If we become aware of the unauthorized collection of Personal Data from minors, incompetent persons, and quasi-incompetent persons without the consent being given in the manner according to the above, we will delete or destroy such data from the Company’s system immediately.

7. Cookies

We may place cookies on your device and use them to automatically collect your Personal Data when you visit the Website.

Cookies are small pieces of data sent from a website that are stored on your computer. They help record the User’s browsing activities conducted on the Company’s website, such as preferred languages, list of favorites, most common use, and other settings, to customize the Website to fit your preference and make internet browsing faster and easier.

You can customize your browser settings to block the use of cookies in order to prevent your browser from automatically accepting new cookies, but it may affect a quality of usage on the Website or difficulty in making any request or entering into any transaction with us on the Website.

We reserve the right to place cookies on your devices for the purpose of collecting your Personal Data.

You may learn more about cookies on the Website at COOKIE POLICY.

8. Retention Periods and Security Protection Measures

8.1 We will retain your Personal Data for as long as it is necessary to fulfil the purposes specified in this Notice and may retain your Personal Data as long as agreed on in the contract, or in accordance with accounting standard, prescription periods, legal obligations, or establishment or exercise of legal claim as permitted by the law.

8.2 We have provided an examination system for deletion or destruction of Personal Data in the event of the expiration of the retention period, or if such Personal Data is unrelated to or beyond the necessity for the purpose of collecting specified by this Notice.

8.3 We will retain your Personal Data in the form of documents, electronic files, computer systems, or other means with appropriate Personal Data security protection measures against loss, and unauthorized or unlawful access, use, change, modification and disclosure.

8.4 We have limited access of your Personal Data and adopted technology to secure your data from cyber-attacks, unauthorized access to our computer and electronic systems. We further ensure that any processing of your Personal Data by data processors or other third parties will take place under appropriate monitoring.

9. User’s Right as the Data Subject

9.1 Under the PDPA you, as the Data Subject, are entitled to

Request access to, or copies of, your Personal Data collected, used and disclosed by the Company.
Request receive or transfer of your Personal Data, in a form collected by us and readable, usable, and disclosable in an electronic format, to another party (the Company reserves the right to charge you a fee, the amount of which is at our discretion.)
Object to the collection, use, and/or disclosure of Personal Data to the extent permitted by law.
Have your Personal Data deleted, destroyed, or anonymized by any method permitted by law.
Sequester your Personal Data from further use by any method unless the law provides otherwise.
Withdraw your consent given us at any time, unless otherwise restricted by law or contracts. Your withdrawal will not extend to Personal Data to which you have granted consent for processing.
File a complaint with the competent officer authorized under the PDPA in the event that you believe we have violated, or do not comply with, the PDPA.

9.2 We will endeavor to maintain the accuracy and completeness of your Personal Data. When there is a change or modification to your Personal Data or when you detect that your Personal Data is incorrect, you have the right to make corrections thereto.

9.3 The exercise of your rights specified above must comply with law. We reserve the right to refuse any request on grounds permitted by law. In the event that we deny your request, the request and reasons for denial will be recorded in the Personal Data processing record as required by law.

9.4 To exercise your right, you may contact us via the contact information provided hereunder. We will process your request and then inform you of the result within 30 days from the date of receiving your request. Where we refuse your request, you will be informed of the reason accordingly.

10. Notifications, Reminders, and Location Settings

The Company may deliver a notification or reminder to your device. You can opt out of receiving these messages at any time by setting up notifications on your device or by adjusting the notification settings on the Application or by changing the notification settings on your mobile in the notification setting and in the Application.

11. Links To Third Parties

Some of the Company’s online services may contain links to third-party applications or websites. Access to and usage of such applications or websites shall be governed by the privacy notice of such third party. We refuse to be held liable to the User if such applications or websites do not comply with or operate in accordance with a third party’s privacy notice.

12. Amendment

We reserve the right to alter, adjust, and/or modify this Notice in order to comply with applicable guidelines, laws, and regulations. The amended, adjusted, or modified notice shall be announced to you as soon as it becomes effective. Your use of the service after such amendment, adjustment, or modification is posted shall constitute your acceptance of the new notice.

13. Contact Us

Should you wish to exercise any legal rights as specified above or have any questions, concerns, suggestions or complaints with regard to our privacy notice, you can contact us via the following channels:

ImagineHealth Company Limited

2nd Floor, 252 Krung Thonburi Road Soi Sathorn Mansion 1,

Khlong Ton Sai, Khlong San District, Bangkok 10600

Data Protection Officer (DPO)

Email: [email protected]

With Best Regards,

ImagineHealth Company Limited

01 September 2022

Privacy Notice for Patients

The Company, as the data controller under the Personal Data Protection Act B.E. 2562 (A.D. 2019) (“PDPA”), are aware of the importance of protecting the personal data of patients, contacts, emergency contacts, and others who involved with the Company (hereinafter referred to as “you” or “Data Subject”), we therefore announce this Privacy Notice (the “Notice“) to inform you of the protection of your personal data that is collected, used, disclosed and/or transferred (“process” or “processing”) to any other relevant persons by the Company.

We ensure that the processing of your personal data will be secured by security protection measures of our standard. We will not process your personal data for purposes other than those specified in this Notice unless you consent thereto.

1. Definitions

“Personal Data” refers to any information that identifies or can be used to identify you, which is collected by the Company as specified in this Notice.

“Sensitive Data” refers to personal data classified as sensitive data under the PDPA that the Company is permitted to collect, use, disclose, and/or transfer with your explicit consent, e.g., the information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, a natural person’s sexual orientation or criminal record, or data concerning health, disabilities, trade union membership, genetic data, biometric data, and other data that affect the Data Subject in the same manner.

2. Personal Data Collected by the Company

The Company will collect, use, disclose and/or transfer your Personal Data which includes, but is not limited to, the following:

2.1 General Personal Data

Personal information, e.g., title, rank, position, first name, middle name, last name, age, date of birth, gender, photograph, nationality, country of residence, national ID card number, passport number, signature, and marital status.
Contact information, e.g., address, mobile phone number, home phone number, and email address.
Service information, e.g., record of doctor’s appointments, room requirements and other additional services.
Educational information, e.g., education background.
Information appearing on legal documents, e.g., national ID card, passport, house registration, driver’s license, government official identification card, certificate of name/surname change, marriage certificate, divorce certificate, and birth certificate.
Contact information and emergency contact information, e.g., first name, middle name, last name, relationship with patients, and mobile phone number.
Information about the person who has the authority to act on behalf of Data Subject (legal representative, guardian, and curator), e.g., name, surname, and national ID card.
Financial information, e.g., billing information, credit or debit card information, and bank account details.
Information on news subscriptions and marketing activities, e.g., seminar enrollment and promotion registration.
Information from the Company’s websites such as IP address, cookies, online doctor appointment, and online doctor consultation.

2.2 Sensitive Data

The Sensitive Data that we will collect, use, disclose and/or transfer, e.g., information concerning religion, health, disabilities, genetic or biometric data, health history, record of medication/food allergy, treatment result, physical examination result, laboratory result, diagnosis result, medical record, medical certificate, surgical record, radiograph imaging, blood type, picture/audio/animation from medical/surgery/operation procedures, as well as, information that appears in the copy of national ID card, e.g., religion and blood type. We will process your Sensitive Data only to the extent required by law or with your prior explicit consent.

3. Source of Your Personal Data

We may collect Personal Data you voluntarily release to us, whether through company service request forms, social media accounts, phone calls, or other forms filled out through the company’s websites and applications such as appointment forms, inquiry forms, product purchase or service request forms, news subscription forms, including wearable medical devices.

We may receive your Personal Data from other sources, e.g., your family members or intimate persons, any other third party assigned by you to disclose your Personal Data, and company’s, affiliated companies, representatives, or alliances of the company.

4. Purposes and Legal Bases

4.1 We will process your personal data based on legal bases as provided below:

We rely on contractual basis to process your Personal Data in order to, for instance,

review your various application requests before entering into a contract;
medical treatment rights’ claim,
request payment;
issue invoices and/or receipts;
communicate for the purchase of products and/or services;
perform contractual obligations;
deliver products or services;
proceed to collect or receive payment of products or services.

We rely on legitimate interest to process your personal data in order to, for instance,

verify your identity;
send medical appointment reminders;
collect contact information for future inquiries in case an emergency arises and the patient is unable to provide their own information;
provide or deliver services as requested;
monitor and review the performance of a contractual obligation;
provide post-sales services;
manage customer relationship;
send and follow up a questionnaire to assess customers’ service satisfaction;
verify and confirm your identity before entering into transactions or contracts;
financially and internally audit;
monitor the accuracy of payments, billing, refunds, and compensation;
monitor compliance with the company’s regulations;
investigate or verify facts;
consult for establishment of legal claim or proof in legal process; and
Your Personal Data may be disclosed to lawyers, legal and tax consultants, external auditors, internal auditors, financial auditors, and any other consultants involved in the process of completing the purposes specified above.

We rely on legal obligations to process your Personal Data in order to comply with the laws related to medical facilities, for instance, new patient registration, doctor’s appointment, medical services, diagnosis, medical treatment, patient examination, preliminary physical examination, collection and use of contact person’s information to approve of or deny the request for medical treatment, medical benefit claim, and ethical and professional compliance.
We rely on other legal obligationsto process your personal data in order to, for instance, collect Personal Data as required by law, disclose or submit Personal Data to government agencies as required by law, and comply with applicable laws, regulations, orders of competent authorities, and court orders.
We rely on vital interests to process your personal data in order to prevent and suppress danger to life, body, or health, for instance, emergency contact.
In the event that you have given your explicit consent, we will process your Personal Data to send news, advertisements, notifications, benefits and promotions of products and services, beneficial campaigns or invitations to the Company’s activities via all communication channels that you have provided to the Company.

4.2 We will process your Sensitive Data based on legal bases as provided below:

We rely on legal obligations to process your Sensitive Data in order to achieve the objectives relating to preventive or occupational medicine, medical diagnosis, health or social services, medical treatments, and health management, for instance:
- Diagnosis and medical treatment;
- Symptoms examination and preliminary physical examination;
- Use of your data for the purpose of laboratory diagnostics;
- Disclosure of your data to external laboratories or an external radiology room to conduct experiments and diagnosis;
- Processing of genetic data to verify identity or relationships before the process of organ transplantation; and
- Compliance with ethics and professional ethics.
We rely on public health purposes such as processing of your health data for purposes of healthcare service quality improvement, contagion control and prevention.
We rely on the necessity to process your Sensitive Data in order to establish and exercise legal claim as permitted by law, for instance, collecting patients’ medical expenses, invoicing, requesting patients to pay off the invoice, issuing a receipt, and examining patient’s billing and debt payment status.
We rely on vital interests to process your Sensitive Data in order to prevent and suppress dangers to life, body, or health such as emergency contact.
In the event that you have given your explicit consent, we will process your Sensitive Data for the purposes set forth in each of the following consent:

Use of a copy of your national ID card that contains Sensitive Data such as religion and blood type to verify your identity;
Disclosure of your health data to hospitals or medical facilities for the purpose of patient referral that is not emergency case;
Disclosure of your health data and medical certificate to insurance company to claim your health insurance benefit;
Disclosure of your health data and medical certificate to your embassy, employer, agency, organization, governmental agencies, or any relevant person to collect payments for your medical services;
Disclosure of your health data to insurance company as requested by you or the insurer for the purpose of entering into an insurance agreement;
Disclosure of your health data to third parties such as your family members, relatives, dependents, or intimate persons upon their request;
Disclosure of your health data, medical certificate and health record to the airline for Fit for Air Travel;
Disclosure of your health data to our business partners for purposes of developing medical products;
Processing of your health data, biological samples, and the data obtained from such samples, and disclosure of such data to external laboratories for research and academic purposes.;
De-identify your health data, biological samples, and the data obtained from such samples to be unidentifiable data for research and academic purposes.;

5. Disclosure of Your Personal Data

We will not disclose your Personal Data for purpose other than purposes specified herein, unless having been consented to do so.

Personal Data that you have provided to us may be transferred outside Thailand and disclosed to our international agents or partners that you have contacted for our services. We will endeavor to ensure that your right to privacy is protected by security protection measures of our standard.

We may disclose your Personal Data to our group companies and affiliates, vendors, business partners, or third parties, e.g., insurance companies, financial institutions, primary doctors, medical professionals, medical specialists, and/or medical practitioners, medical technology clinic, manufacturers or distributors of drugs and medical supplies, embassy, person who handle international travel, customer service provider, marketing, advertising and communication service providers, information system providers, cloud service provider, nearby hotels that are alliance with us, transport service providers, document storage service providers, debt collection service providers, accounting and legal consultants, external auditors, internal auditors, financial auditors, and your family, relatives, intimate persons, agencies or employers, and internal organizations such as Bureau Veritas, Joint Commission International (JCI), and Healthcare Accreditation Institute (Public Organization) (HAI). We may proceed any other actions to complete the purposes specified in this Notice in order to benefit our services.

We will endeavor to ensure that these individuals and organizations will process your Personal Data strictly in accordance with this Notice and as permitted by law.

Where it is necessary to disclose your Personal Data in order to comply with the law, court orders, or orders of any governmental or regulatory agency such as embassy, the Immigration Office, or to relevant agencies in order to verify your Personal data to prevent fraud or corruption, we reserve the right to do so without your prior consent.

6. Collection of Personal Data of Minors, Incompetent Persons, and Quasi-Incompetent Persons

Where we must process the Personal Data of minors, incompetent persons, or quasi-incompetent persons, we shall have their parents, legal representative, guardian, or curator, as the case may be, consented on behalf of them.

If a minor or a quasi-incompetent person is legally permitted to give consent on their own behalf, we shall require combined consent from them and their legal representative.

If you become aware of the unauthorized collection of Personal Data from minors, incompetent persons, and quasi-incompetent persons without the consent being given in the manner according to the above, you can exercise rights of the Data Subject as the legal representative under the PDPA.

7. Retention Periods & Security Protection Measures

7.1 We will retain your Personal Data for as long as it is necessary to fulfil the purposes specified in this Notice and may retain your Personal Data as long as agreed on in the contract, or in accordance with accounting standard, prescription periods, legal obligations, or establishment or exercise of legal claim as permitted by the law.

7.2 We have an examination system for deletion or destruction of Personal Data in the event of the expiration of the retention period, or if such Personal Data is unrelated to or beyond the necessity for the purpose of collecting specified by this Notice.

7.3 We will retain your Personal Data in the form of documents, electronic files, computer systems, or other means to ensure that your Personal Data is protected with secured and trustworthy security protection measures of international standard against loss, and unauthorized or unlawful access, use, change, modification, and disclosure.

7.4 We have limited access of your Personal Data and adopted technology to secure your data from cyber-attacks, unauthorized access to our computer and electronic systems. We further ensure that any processing of your personal data by data processors or other third parties will take place under appropriate monitoring.

8. Data Subject’s Right

8.1 Under the PDPA, you, as the Data Subject, are entitled to:

Request access to, or copies of, your Personal Data collected, used and disclosed by the Company.
Request receive or transfer of your Personal Data, in a form collected by us and readable, usable, and disclosable in an electronic format, to another party (the Company reserves the right to charge you a fee, the amount of which is at our discretion.)
Object to the collection, use, and/or disclosure of Personal Data to the extent permitted by law.
Have your Personal Data deleted, destroyed, or anonymized by any method permitted by law.
Sequester your Personal Data from further use by any method unless the law provides otherwise.
Withdraw your consent given us at any time, unless otherwise restricted by law or contracts. Your withdrawal will not extend to Personal Data to which you have granted consent for processing.
File a complaint with the competent officer authorized under the PDPA in the event that you believe we have violated, or do not comply with, the PDPA.
We will endeavor to maintain the accuracy and completeness of your Personal Data. When there is a change or modification to your Personal Data or when you detect that your Personal Data is incorrect, you have the right to make corrections thereto.

8.2 The exercise of your rights specified above must comply with law. The Company reserves the right to refuse any request on grounds permitted by law. In the event that we deny your request, the request and reasons for denial will be recorded in the personal data processing record as required by law.

8.3 The exercise of your rights specified above must comply with law. The Company reserves the right to refuse any request on grounds permitted by law. In the event that we deny your request, the request and reasons for denial will be recorded as required by law

8.4 To exercise your right, you may contact us via the contact information provided hereunder. We will process your request and then inform you of the result within 30 days from the date of receiving your request. Where we refuse your request, you will be informed of the reason, accordingly.

9. Amendment

We reserve the right to alter, adjust, and/or modify this Notice in order to comply with applicable guidelines, laws, and regulations. If such changes occur, we will inform you of the amended, adjusted, or modified content in the designated channel as soon as it becomes effective. New Notice will only apply to you upon your use of service after the revision.

10. Contact Us

ImagineHealth Company Limited

2nd Floor, 252 Krung Thonburi Road Soi Sathorn Mansion 1,

Khlong Ton Sai, Khlong San District, Bangkok 10600

Data Protection Officer (DPO)

Email: [email protected]

With Best Regards,

ImagineHealth Company Limited

01 September 2022

Privacy Notice for Vendors

The Company, as the data controller under the Personal Data Protection Act B.E. 2562 (A.D. 2019) (“PDPA”), are aware of the importance of protecting your personal data as our business partners, contracting parties at the present, in the past, and possibly in the future contract including employees, personnel, officers, representatives, agents, authorized directors of the juristic person, directors, contact persons and any other natural persons acting on behalf of the juristic persons who are our business partners, witnesses, and other related persons. (hereinafter referred to as “you” or “Data Subject”), we therefore announce this Privacy Notice (the “Notice“) to inform you of the protection of your personal data that is collected, used, disclosed and/or transferred (“process” or “processing”) to any other relevant persons by the Company.

We ensure that the processing of your personal data will be secured by protection measures of our standard. We will not process your personal data for purposes other than those specified in this Notice unless you consent thereto.

1. Definitions

“Personal Data” refers to any information that identifies or can be used to identify you, which is collected by the Company as specified in this Notice.

“Sensitive Data” refers to Personal Data classified as sensitive data under the PDPA that the Company is permitted to collect, use, and/or disclose with your explicit consent, e.g., the information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, a natural person’s sexual orientation or criminal record, or data concerning health, disabilities, trade union membership, genetic data, biometric data, and other data that affect the Data Subject in the same manner.

2. Personal Data Collected by the Company

The Company will collect, use, disclose and/or transfer your Personal Data which includes, but is not limited to, the following:

2.1General Personal Data

Personal Information, e.g., name, surname, title, nationality, gender, age, date of birth, photograph, identification number, tax identification number, professional license number, etc.
Contact information, e.g., telephone numbers, fax number, address, e-mail, etc.
Work Information, e.g., occupation, job title, etc.
Financial information, e.g., bank account numbers, etc.
Information appearing on legal documents, e.g., a copy of an ID card, copy of professional license, copy of any licenses, etc.

2.2 Sensitive Data

The Sensitive Data that we will collect, use, disclose and/or transfer is the information that appears in the copy of the national ID card, e.g., religion, ethnicity, and blood group. We will only process your Personal Data with your prior explicit consent or as required by law.

3. Source of Your Personal Data

We may collect your Personal Data from the Personal Data you have provided us through communication channels including for procurement of goods and services, exchanging business cards, providing your information through electronics platforms or channels, etc. We also may receive your Personal Data from other sources such as a referral by other persons or medical personnel that has provided you to us, your close acquaintances and public search, etc.

4. Purposes and Legal Bases

4.1 We will process your Personal Data based on legal bases as provided below:

We rely on contractual obligations to process your Personal Data in order to:
- Complete contractual obligations
- Review your various application requests before entering into a contract e.g.
  1. – Consider procurement selection
  2. – Consider qualification before entering into the contract
  3. – Consider or enter into a contract
- Communicate for the purchase of goods and/or services
- Perform in accordance with contracts or contractual obligations
- Act in relation to collecting or paying for goods or services
- Deliver or receive of goods or services, etc.

We rely on legitimate interest to process your Personal Data for the following purposes:

Procurement
Verification of receipt of goods or services
Inspection and follow-up on the performance of the contract
Verification of the compliance or quality of the goods or services
Verification and confirmation of identity in connection with entering into transactions or contracts
Performance evaluation
Investigation or fact verification
Consult for the establishment of legal claim or proof in legal process
Disclosure to an external service provider for accounting, financial, and IT service purpose

Your Personal Data may be disclosed to lawyers, legal and tax consultants, external auditors, internal auditors, financial auditors, and any other consultants involved in the process of completing the purposes specified above.

We rely on legal obligations to process your Personal Data in order to comply with laws related our business operation such as carrying out any accounting and financial activities, such as audits, notification and collection of debts, issuing tax invoices and evidence of various transactions as required by law, collection of Personal Data as required by law, disclose or submit Personal Data to government agencies as required by law, compliance with applicable laws, regulations, orders of competent authorities, and court orders, payment of legal fee, establishment or exercise legal or judicial claim, etc.
We rely on vital interests to process your Personal Data in order to prevent and suppress dangers to life, body or health such as emergency contact, and contagion control and prevention.

4.2 In the event that you have given your explicit consent, we will process your Sensitive Data to use a copy of your national ID card that contains Sensitive Data such as religion and blood type to verify your identity.

5. Disclosure of Your Personal Data

We will not disclose your Personal Data for purpose other than purposes specified herein, unless having been consented to do so.

However, we may disclose your Personal Data to our group companies and affiliates or third parties in order to carry out accounting audit, seeking legal advice, litigation, and taking and any other action necessary for the purposes stated in this Notice for the benefit of our operation.

We ensure that these individuals will process your Personal Data strictly in accordance with this Notice and as permitted by law.

Where it is necessary to disclose your Personal Data to any governmental or regulatory agency such as the Revenue Department, or disclose information in accordance with the order of any government agency or regulator, we reserve the right to do so without your prior consent.

6. Retention Periods & Security Protection Measures

6.1 We will retain your Personal Data for as long as it is necessary to fulfil the purposes specified in this Notice and may retain your Personal Data according to valid agreements, accounting standards, prescription periods, legal obligations, establishment or exercise of legal claim as permitted by the law.

6.2 We have an examination system for deletion or destruction of Personal Data in the event of the expiration of the retention period, or if such Personal Data is unrelated to or beyond the necessity for the purpose of collecting specified by this Notice.

6.3 We will retain your Personal Data in the form of documents, electronic files, computer systems, or other means with appropriate Personal Data security protection measures against loss, and unauthorized or unlawful access, use, change, modification and disclosure.

6.4 We have limited access of your Personal Data and adopted technology to secure your data from cyber-attacks, unauthorized access to our computer and electronic systems. We further ensure that any processing of your Personal Data by data processors or other third parties will take place under appropriate monitoring.

7. Data Subject’s Right

7.1 Under the PDPA you, as the Data Subject, are entitled to:

Request access to, or copies of, your Personal Data collected, used, and disclosed by us.
Request receive or transfer of your Personal Data, in a form collected by us and readable, usable, and accessible in an electronic format, to another party (the Company reserves the right to charge you a fee, the amount of which is at our discretion.)
Object to the collection, use, and/or disclosure of Personal Data to the extent permitted by law
Have your Personal Data deleted, destroyed, or anonymized by any method permitted by law.
Sequester your Personal Data from further use by any method unless the law provides otherwise.
Withdraw your consent given to us at any time, unless otherwise restricted by law or contracts. Your withdrawal will not extend to Personal Data to which you have granted consent for processing.
File a complaint with the competent officer authorized under the PDPA in the event that you believe we have violated, or do not comply with, the PDPA.

7.2 We will endeavor to maintain the accuracy and completeness of your Personal Data. When there is a change or modification to your Personal Data or when you detect that your Personal Data is incorrect, you have the right to make corrections thereto.

7.3 The exercise of your rights specified above must comply with law. We reserve the right to refuse any request on grounds permitted by law. In the event that we deny your request, the request and reasons for denial will be recorded in the Personal Data processing record as required by law.

7.4 To exercise your right, you may contact us via the contact information provided in this Notice. We will process your request and then inform you of the result within 30 days from the date of receiving your request. Where we refuse your request, you will be informed of the reason, accordingly.

8. Amendment

10. Contact Us

ImagineHealth Company Limited

2nd Floor, 252 Krung Thonburi Road Soi Sathorn Mansion 1,

Khlong Ton Sai, Khlong San District, Bangkok 10600

Data Protection Officer (DPO)

Email: [email protected]

With Best Regards,

ImagineHealth Company Limited

01 September 2022