Personal Data Privacy Policy
1. Personal Data

The Nitrocellulose Group is one of the world’s leading manufacturers of industrial nitrocellulose, a film forming resin which is widely used in the inks and coatings market. It is a high quality, supremely flexible material that demonstrates outstanding functionality, excellent value for money and high standards of safety. It delivers genuine competitive advantages.

Above all, it creates end-products of unrivalled clarity,that meet and surpass increasingly demanding industry standards. By imposing tight limits on the degree of nitration obtained and selecting the appropriate reaction parameters the precise solubility characteristics of the final product can be determined.

1.1 The Characteristics of Personal Data
In this document:
“Personal Data” means any information relating to a Person, which enables the identification of such Person, whether directly or indirectly, but not including the information of the deceased Persons in particular.

“Sensitive Personal Data” means Personal Data pertaining to racial, ethnic origins, political opinions, cult, religious or philosophical beliefs, sexual orientation, criminal records, health data, disability, trade union information, genetic data, biometric data (such as fingerprints or facial recognition data) or of any data which may affect the data subjects in the same manner, as prescribed by the Personal Data Protection Committee

1.2 The Collection of Personal Data
The Companies may collect your Personal Data as follows:

General Personal Data:

2. The respect of Personal privacy

The Companies respect Data Subjects’ right of their Personal Data and is also aware of the Data Subjects’ intention for the due protection of their Personal Data. Any Personal Data submitted to the Companies will be used only for the stated purposes. The Companies have strict security measures and a prevention not to let the unauthorized parties from accessing and using your personal data.

3. The Collection of Personal Data

In the direct collection, use, and disclosure of your Personal Data, the companies shall solicit your consent should it be legally required and shall use the Personal Data only as necessary and only in accordance with the Companies’ specified purposes.

However, the Companies may collect your Personal Data from any other sources, such as from various social media, but only in necessity and carried out in accordance with legal requirements.

4. Purposes for the collection, use and disclosure of Personal Data

The Companies collect, use, and disclose your Personal Data for the following purposes: The Personal Data collected by the companies in relation to the above-mentioned purposes are required in compliance with contractual obligations or in accordance with applicable laws. In case of refusal to provide the required Personal Data, it may be considered as an infringement of relevant laws or may cause the Companies not to be able to manage or execute contractual obligations or facilitate services for you.

However, should any modifications to the stated purposes for the collection of Personal Data subsequently occur, the Companies will duly inform you as well as fulfill other legal obligations, including the recording as evidence of the amendment of the purposes stated in this Policy.

5. The Personal Data retention period

The Companies will retain your Personal Data only for the necessary duration, and will collect, use and disclose your Personal Data, as defined in this Policy, in accordance with the duration criteria, namely the period during which you are still related to the Companies as client, supplier and related persons, or business partner, and may still retain your Personal Data as long as needed for legal compliance or as per legal prescription, for the establishment of legal claims, legal compliance or exercise of legal claims, or defense of legal claims, or for other purposes in accordance with policies and the internal regulations of the Companies.

If it is not possible to specify the Personal Data retention period, the Companies will retain the Personal Data as may be expected per data retention standards (such as the longest legal prescription of 10 years).

6. Security Measures

The Companies have in place adequate and strict security measures, in accordance with Policy and Guidelines on Information Technology of the Companies, to prevent Personal Data, loss, access, destruction, use, alteration, correction, and to prohibit unauthorized or unlawful use of Personal Data.

7. Your Rights as a Data Subject

As a Data Subject, you have the rights as prescribed in the Personal Data Protection Act, B.E. 2562 (2019) and other rights as follows:

7.1 Right to withdraw consent
You have the right to withdraw consent for the processing of your Personal Data as submitted to the Companies, but not if the consent withdrawal is restricted by law or by contract of benefit to you as a Data Subject. However, the withdrawal of consent shall not affect the processing of Personal Data to which you have already legally consented.

7.2 Right to access to the Personal Data
You are entitled to request access to and obtain a copy of your Personal Data, under the Companies’ care and responsibility, as well as to request the disclosure of the acquisition of your Personal Data without your consent.

7.3 Right to request for sending or transferring the Personal Data (Right to data portability)
You have the legal right to request the Companies to transfer your Personal Data.

7.4 Right to object to the collection, use, or disclosure of Personal Data
You have the right to object to the processing of your Personal Data, namely the collection, use, or disclosure of your Personal Data as prescribed by law.

7.5 Right to request the erasure of Personal Data (Right to be forgotten)
You have the legal right to request the Companies to erase, destroy, or to anonymize your Personal Data.

7.6 Right to restrict the use of Personal Data.
You have the legal right to request the Companies to suspend the use of your Personal Data.

7.7 Right to request for the correction of the Personal Data
Should you discover that your Personal Data kept by the Companies is not correct or has been modified, you have the legal right to request the Companies to correct them so that your Personal Data is accurate, up-to-date, complete, and will not incur any misunderstandings.

7.8 Right to be informed in case of the modification of the Privacy Notice
The Companies may consider and modify as appropriate this Privacy Notice to ensure that your Personal Data is well protected.

7.9 Right to Complain
You have the right to complain to authorized officials as prescribed by the Personal Data Protection Act, B.E. 2562 (2019) in case of the Companies’ infringement or non-compliance with the Act.
In the event that the Data Subject lodges their request to exercise their rights as prescribed by the Personal Data Protection Act, B.E. 2562 (2019), upon reception of such request, the companies will further proceed within the duration of time as prescribed by the Act. However, the Companies reserve the right to deny or not to proceed with the request as prescribed by law in case that the Data Subject has chosen to provide to the Companies only certain Personal Data which may cause the Companies not to be able to provide full services. Moreover, the Companies may not be able to collaborate with or to provide services to the Data Subject if they do not consent to the provision of information as required by the Companies.

8. The Disclosure of Personal Data to a Third Party

The Companies may have the need to disclose Personal Data to its subsidiary or to other persons or business units that are strategic allies in Thailand or in a foreign country cooperating with the Companies in the procurement of various products or services, or out of necessity as prescribed by terms and conditions of the Companies, or in case of reorganization, merging or sales of the Companies and may require the disclosure of the Personal Data to Thai authorities or Public Organizations concerned as prescribed by law or by court order or by the order of authorized officials for which the Personal Data will be kept confidential, either in paper form or electronic form, including during its transfer.

However, in case of an international transfer of Personal Data, the Companies will strictly comply with the Personal Data Protection Act, B.E. 2562 (2019).

9. Data Protection Officer

The Companies have complied with the Personal Data Protection Act, B.E. 2562 (2019) by appointing a Data Protection Officer (DPO) to review the Companies’ collection, usage, and disclosure of Personal Data for conformance with the Personal Data Protection Act, B.E. 2562 (2019) including other related laws.

10. Contact channels

Enquires or questions on the Personal Data Protection can be addressed to the following channels:

Nitrocellulose Group
Address: 24 Rama 1 Road, Rongmuang, Pathumwan, Bangkok 10330
Tel: 02-6136970

Data Protection Officer (DPO)
Address: 24 Rama 1 Road, Rongmuang, Pathumwan, Bangkok 10330

11. Amendment of the Policy and Guideline on Personal Data Protection

The Company may, from time to time, review this Policy for compliance with the changing guidelines and relevant laws. In case of changes thereto, the Company will provide a public notification through appropriate channels

Given this day, 31 May 2022

(Mr.Pichate Viprakasit)