Data privacy // Klüber Lubrication ประเทศไทย

Data Protextion Statement

1. Controller

Controller within the meaning of data protection law is:

Klüber Lubrication Thailand Co., LTD

5 Dr. Gerhard Link Building, 12th Floor,
Soi Krungthepkreetha 4 (B.Grimm),

Krungthepkreetha Road, Huamark,
Bangkapi, Bangkok 10240

Phone: +66 (0) 2 792 2888
Fax: +66 (0) 2 792 2800

Email: marketing@th.klueber.com

- In the following also "Klüber

You can contact our data protection team as follows: privacydata_klth@klueber.com

2. Personal Information

“Personal Information” generally means any information that identifies you as an individual, whether directly or indirectly, and any other information we associate with it. We collect a few categories of information, from a few different sources:

2.1. Profile information and other content you voluntarily provide us, which may include:

Username and password
Contact information when you register on our Sites, such as your name, street address, demographic information (such as your gender), date of birth, mobile and home phone number, and/or email address.
You may also provide us information about other people, such as when you direct us to send a gift on your behalf.
Any content or contributions you post in a public space on the Sites. This includes comments, videos and photos that you might submit. If you contact us through a social media site, we may collect your social media identifier.
Any information you provide in communications with us, such as via social media, e-mail or our customer call center.
Payment information, such as when you make a purchase with us or make a donation or contribution and we need your billing information to process the transaction.

2.2. Information that is passively collected when you use the Sites, such as by our web servers and by third party analytics tools we use:

Our system logs may record certain information about visitors to our Sites, including the web request, Internet Protocol (“IP”) address, device and mobile ad identifiers, browser information, interaction with the Sites, pages viewed, app usage, and other such information; we may collect similar information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients.
We use certain cookies, pixel tags and other technologies to help us understand how you use the Sites and enable us to personalize your experience. We may ask advertisers or other third party partners to serve ads or services to your devices, which rely on cookies or similar technologies placed on our Sites.
We may detect the physical location of your device by, for example, using GPS information collected by mobile apps or location information shared by your web browser. We collect this information for purposes of enhancing or facilitating our services, such as enabling certain functionalities of the Sites that can provide you with information about promotions or relevant product information near you. We may use your device’s physical location to better understand how our Sites and other services and functionality are being used and to provide you with relevant and personalized location-based services and content, including advertising. Should you wish to opt out of the collection of this information, please adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. Please consult your device settings for further information.

3. How we collect, use or disclose your personal data?

We only collect, use or disclose your personal data where it is necessary or there is a legal basis for collecting, using or disclosing it. This includes where we collect, disclose your personal data based on legitimate grounds, contract, consent, and other legal basis.

We may use Personal Information, as permitted by law, for the following business purposes:

to respond to your inquiries and fulfill your requests
to communicate with you about and to process orders, purchases, returns, services, donations, promotions, campaigns, programs, contests, sweepstakes, rewards, and accounts
to inform you about our brands, products, promotions, events, or other promotional purposes
to re-contact you if we have not heard from you in a while
to send you advertising/promotional material from any of our affiliates, and on behalf of our promotional and strategic partners
to improve your experience with our products and services, such as by personalizing your experience with us
to allow you to participate in polls, sweepstakes, promotions, contests and other promotions and to administer these activities
to deliver gift cards or gifts to others in accordance with your instructions
to permit you to participate in social sharing, including live social media feeds
to perform analytics, quality control, market research, and determine the effectiveness of our websites, mobile applications, promotional campaigns, and develop new products and services

We may also use Personal Information as we believe to be necessary or appropriate for certain essential purposes, including:

to comply with applicable law and legal process
to respond to requests from public and government authorities, including public and government authorities outside your country of residence
to detect, prevent, or investigate potential security incidents or fraud
to facilitate the functionality of our mobile applications and websites
to provide important product safety information and notice of product recalls
to enforce our terms and conditions
to protect our operations or those of our affiliates
to protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others
to allow us to pursue available remedies or limit the damages that we may sustain

If you submit any Personal Information relating to other people in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

It is important to note that failure to provide us with your Personal Information under these circumstances may result in us being unable to enter into a contract with you, to perform our contractual obligations, or to comply with legal obligations, or found to be in violation or non-compliance with any applicable law or regulation.

4. Legal Bases for processing of data

We may rely on the following legal bases to process your personal data:

4.1. Contractual

We may process your personal data to initiate or fulfil a contract with you, in order to, communicate with you about our services, respond to inquiries or requests.

4.2. Legal Obligations

We may process your personal data by, disclosing your personal data, to government agencies, courts, regulatory agencies or other authorities and authorized officers.

4.3. Legitimate Interests

We may process your personal data where our interests or those of third parties outweigh your fundamental rights in order to manage our business relationship with you (surveys or maintain security e. g. CCTV records).

4.4. Consent

In certain cases, we may ask for your consent to collect, use or disclose your personal data to maximize your benefits and/or to enable us to provide services to fulfil your needs for the following purposes, which include but not limited to:

collect, use or disclose your sensitive personal data as necessary (e.g. to use face recognition or your identification card photo (which contains your sensitive personal data, namely religion and/or blood type) for verification of your identity before continuing the transaction and for Know Your Customer (KYC) process);
collect and use your personal data and any other data to conduct research and analyze for the greatest benefits in developing products and services to truly fulfil your needs and/or to contact you for offering products, services and benefits exclusively suitable to you;
contact you to provide financial advice and offer our products or services which may interest you (in case the consent is required under the PDPA);
disclose your personal data and any other data to companies in Klüber Group as shown on this page and or www.klueber.com/th/th/ and our trusted business partners for the following purposes:
- researching, conducting statistical data, developing, analyzing products, services, and benefits to fulfil your needs; and
- contacting you for offering or providing products, services, and benefits suitable to you;
send or transfer your personal data and sensitive personal data overseas, which may have inadequate personal data protection standards (unless the PDPA specifies that we may proceed under other lawful basis or without obtaining consent);
send your identification card data to the Department of Provincial Administration for verifying the status of your identification card, which is one of the factors to verify and identify your identity before continuing your transaction with us;
when you are classified as a minor, incompetent or quasi-incompetent whose consent must be given by their parent, guardian, or curator (as the case may be) (unless the PDPA specifies that we may proceed without obtaining consent); and/or
other activities which we may require your consent.

5. What Personal Data we collect, use

The type of personal data, namely personal data and sensitive personal data, which we collect, use or disclose, varies depending on the scope of products and/or services that you may have used or had an interest in. The type of personal data and sensitive personal data shall include but not limited to:

Category	Examples of personal data
Personal details	Title Given name, middle name, surname, hidden name (if any) Gender Nationality
Contact details	Mailing address E-mail address Phone number Mobile number Facsimile number Name of representatives or authorized persons/directors acting on behalf of our customers Social media accounts, including profile data, photo and other identifier for electronic communication Business address Business phone number Contact details of reference person
Employment details	Occupation Employer’s details and workplace Position
Market research and marketing data	Customer survey Data and opinions expressed when participating in market research (e.g. your responses to questionnaires, surveys, requests for feedbacks, and research activities) Details of services you receive and your preferences Inferences about you based on your interactions with us Communication preferences and details or content of your communications with us
Geographic data and data relating to your device and your software, and technical details	Your GPS location IP address Technical specifications and uniquely identifying data (e.g. location, web beacon, log, device ID and type, network, connection details, access details, access date and times, duration of usage, cookies, search history, browsing details, IMEI (International Mobile Equipment Identity) of mobile phone or other unique device identifier, details relating to mobile phone, and other technology on devices you use)
Investigation data	Data for due diligence checks (e.g. data relating to Know Your Customer (KYC) or Customer Due Diligence (CDD)) Data for risk management or Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) checks
User login, subscription data, and profile details	Login data for using our system, applications Username, password and other verification code Interests, preferences and activities
Usage details	Data relating to your usage of websites, platforms, products and services Data relating to your usage and interaction with our advertising (including content viewed, links clicked, and features used)
Data concerning security	Visual images Event/Atmosphere picture Personal appearance Detection of any suspicious or unusual activity Video recordings
Other data	Records of correspondence and other communications between you and us, in whatever manner and form, including but not limited to phone, email, live chat, instant messages and social media communications Data that you provide to us through any channels

6. Source of Personal Data

We may collect your personal data in a variety of ways:

Data obtained by us from companies within the Klüber Group, business partners, and/or any other persons who we have legal relationship with.
Data obtained by us from persons related to you.
Data obtained by us from corporate customers as you are director, authorized person, attorney, representative or contact person.
Data obtained by us from governmental authorities, regulatory authorities; financial institutions, credit bureau and/or third party service providers (e. g. data that’s is publicly available.

7. Disclosure of Personal Data

We may disclose your personal data to our subsidiaries abroad. An overview of subsidiaries within the corporate group is available here: https://www.klueber.com/de/en/company/locations/

We may also disclose or transfer your personal data within the Klüber Group, government agencies, courts, regulatory agencies or authorized officers in order to comply with judicial proceedings or other legal obligations, including laws regulations, rules, directives, orders, instructions and requests from any governmental, law enforcement or regulatory agencies.

8. International Transfer of Personal Data

Due to the fact, that Klüber Lubrications is a global company we may transfer your personal data internationally (e. g. transferring data to other companies within the Klüber or to cloud servers overseas for the purpose of the provision of service) When sending or transferring your personal data, we will always exercise our obligation in accordance with the PDPA as well as the local data protection laws to have your personal data to our reliable business partners, service providers or other recipients by the safest method in order to maintain and protect the security of your personal data.

If the destination countries do not have an adequate data protection standard, we will proceed to transfer personal data as specified by the PDPA and will put in place the protection measures of such personal data as necessary and appropriate.

9. Retention Period and Security Protection Measures

We will maintain and keep your personal data only for as long as necessary for purposes under this privacy policy, or to comply with legal obligations, the establishment or exercise of legal claims or while you as a customer have ended the relationship with us (e. g. after you closed your account with us, or you terminated the services provided by us). We will keep your personal data for a period that is appropriate and necessary for each type of personal data and for the purposes as specified by the PDPA.

10. Your rights

The PDPA aims to give you more control of your personal data. You can exercise your rights under the PDPA, details as specified below, through the channels prescribed by us.

10.1. Right to access and obtain copy

You have the right to access and obtain copy of your personal data retained by us, unless we are entitled to reject your request under the laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.

10.2. Right to rectification

You have the right to rectify your inaccurate personal data or to update your incomplete personal data.

10.3. Right to erasure

You have the right to request us to delete, destroy or anonymize your personal data, unless there are certain circumstances where we have the legal grounds to reject your request.

10.4. Right to restrict

You have the right to request us to restrict the use of your personal data under certain circumstances (e.g. when we are pending examination process in accordance with your request to rectify your personal data or to object the collection, use or disclosure of your personal data, or you request to restrict the use of personal data instead of the deletion or destruction of personal data which is no longer necessary as you have necessity to retain it for the purposes of establishment, compliance, exercise or defense of legal claims).

10.5. Right to object

You have the right to object the collection, use or disclosure of your personal data in case we proceed with legitimate interests basis or for the purpose of direct marketing, or for the purpose of scientific, historical or statistic research, unless we have legitimate grounds to reject your request (e.g. we have compelling legitimate ground to collect, use or disclose your personal data, or the collection, use or disclosure of your personal data is carried out for the establishment, compliance, or exercise legal claims, or for the reason of our public interests).

10.6. Right to data portability

You have the right to receive your personal data in case we can arrange such personal data to be in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means. Also, you have the right to request us to send or transfer your personal data to third party, or to receive your personal data which we sent or transferred to third party, unless it is impossible to do so because of the technical circumstances, or we are entitled to legally reject your request.

10.7. Right to withdraw consent

You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us, unless the nature of consent does not allow such withdrawal. The withdrawal of consent will not affect the lawfulness of the collection, use, or disclosure of your personal data based on your consent before it was withdrawn.

You can review and change your consent to use or disclose your personal data for marketing purposes through channels as specified.

10.8. Right to lodge a complaint

You have the right to make a complaint with the Personal Data Protection Committee or their office in the event that we do not comply with the PDPA.

11. Use of Cookies

We may collect and use cookies and similar technologies when you use our products and/or services. This includes when you use our websites, internet banking and banking applications.

The collection of such cookies and similar technologies helps us recognize you, remember your preferences and customize how we provide our products and/or services to you. We may use cookies for a number of purposes (e.g. enabling and operating basic functions, helping us understand how you interact with our websites or emails, or enabling us to improve your online experiences or our communications with you, particularly, to ensure that online adverts displayed to you will be more relevant to you and of your interests), for details please see Cookie Notice .

12. Use of personal data for original purposes

We are entitled to continue collecting and using your personal data, which has previously been collected by us before the effectiveness of the PDPA in relation to the collection, use and disclosure of personal data, in accordance with the original purposes. If you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time.

13. Security

We endeavor to ensure the security of your personal data through our internal security measures and strict policy enforcement. The measures extend from data encryption to firewalls. We also require our staff and third-party contractors to follow our applicable privacy standards and policies and to exercise due care and measures when using, sending or transferring your personal data.

14. How to contact us

If you have any questions or would like more details about our privacy notice, please contact us through the following channels: