This Privacy Statement

This Privacy Statement is issued on behalf of Minor International PCL so when we mention “we”, “us” or “our” in this privacy statement, we are referring to the relevant entity within Minor Group responsible for processing your data.

We will let you know which entity will be the data controller for your data when you use any of our Services.

This Website

The Data Controller of this website is Minor International PLC, with registered address at 88 The Parq Building, 12th Fl. Ratchadaphisek Road, Klongtoey Subdistrict, Klongtoey District, Bangkok Metropolis 10110, Thailand. If you have any questions regarding this Privacy Statement you can reach us via privacy.corporate@minor.com

Please note that our websites are not intended for children and minors and we do not knowingly solicit or collect Personal Data from anyone under the age of 18, other than from a parent or legal guardian with consent. As a parent or legal guardian, please do not allow your children to submit Personal Data without your permission.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

This Privacy Statement also aims to give you information on how Minor Group collects and processes your personal data through your use of this website, and other services provided by Minor Group (“Services”) from which you are accessing this Privacy Statement, including any data you may provide when you use our:

• Online services, such as websites owned or controlled by the Minor Group, web and mobile applications, social media pages, HTML-formatted email messages; or
• Offline interactions, when you visit our offices, reach out via phone, or through other offline interactions.

We use different methods to collect data from and about you including through this website:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide online when you register through our supplier portal, sign up for a newsletter or submit an online form. We collect personal data offline, when you visit our offices, use services within our portfolio of businesses, or submit an online form.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. To learn more, please see our cookie statement for further details.
• Security Systems. When you visit our offices, information may be collected about you through such properties’ closed-circuit television systems, electronic key cards and other security systems.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including business partners, and social media and networking platforms.

This Privacy Statement

Minor Group will process your personal data for different purposes. These data processing may be for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below:

We will use this information for the following purposes:

• Performing our obligations as a publicly listed corporation, such as providing relevant information upon request, disclosure of board members, key personnel and organizational data, preparing financial, risk auditing and tax reporting, and maintaining our banking and credit facilities.
• Development of investor relations, such as maintaining databases of shareholders, existing and potential investors, equity analysts and partner contact information, attending to information requests, consent for email newsletters and alerts, and holding AGM and events.
• Improvement of our services, such as feedback on the operation of our business as part of the contracted relationship between you and us.
• Maintaining our supply chain, such as managing our database of vendors within our organization.
• Perform contracts with our business partners
• Managing stakeholder relations with media, influencers & key opinion leaders, government, and other entities, issuing press releases, news and presentations.
• Management of our insurance policies and the processing of claims.
• Promoting our sustainability initiatives, such as diversity and equality reporting, and supporting volunteering initiatives.
• Responding to whistleblowing complaints.
• Compliance with legal obligations in accordance with applicable laws, such as local privacy laws, prevention of fraud or money laundering, police investigations, and corporate regulations.
• Safety and security to maintain the safety, health, and well-being of stakeholders, and protecting Minor Groups’ assets and employees.

This Website

Feedback, Enquiry and Whistleblowing Forms. To receive and respond to your feedback, requests for information and whistleblowing complaints. The lawful grounds for these processes are your consent and legitimate interest.

Investor Relations. To provide investment community information, issue information and managing subscription to email alerts. The lawful grounds for these processes are the performance of the contract, legitimate interest and user consent.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“Aggregate Data”).

We may collect, use, store and transfer different kinds of personal data about you which we have arranged according to the different purposes as follows:

• Contact information (such as name, email address, mailing address, and phone number);
• Identity data (such as username or similar identifier, nationality, and supporting documents when entering into contracts to fulfill our contractual obligations.)
• Financial information (including company registration information, investments, billing address, and bank account information);
• Demographic data (such as age, gender, country, marital status, dependents, and preferred language);
• Information necessary to fulfill your requests;
• Employment information (such as company name, job title, and work contact information);
• Prior activity participation (such as workshops, and training);
• Copies of your correspondence if you contact us;
• Feedback and survey responses;
• Information collected through closed-circuit television systems, card key and other security systems;
• Information related to your use and interaction with our website and network; and
• Information as requested by government authorities to fulfill our legal obligations.

We do not collect the following special categories of Personal Data about you: religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. We may collect information about criminal convictions and offences as part of our internal risk auditing processes. We may collect data about your health such as occupational safety incidents or other information that you provide to us. We may collect information about race or ethnicity for reporting purposes.

Our goal is to provide you with the highest level of Services, and to do so, we share Personal Data with the following parties:

• Minor Group. We disclose Personal Data to other companies, affiliates and subsidiaries, within the Minor Group for the purposes described in this Privacy Statement, such as addressing feedback, requests for information, maintaining our supply chain, and our business purposes. Minor International PLC is the party responsible for the management of the jointly controlled Personal Data.
• Strategic Business Partners. We disclose Personal Data and Other Data to business partners such as corporate sustainability assessors and potential investors.
• Service Providers. We disclose Personal Data to third-party service providers for the purposes described in this Privacy Statement. Examples of service providers include companies that provide website hosting, data analysis, information technology and related infrastructure provision, human resource management companies, accounting and external auditing firms, consultants, insurance brokers and banks.
• Public administrations and polices bodies. We disclose Personal Data to public administrations and polices under requirement in order to comply with obligations under the regulations and cooperate with these entities in the performance of their duties.

We require all third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your Personal Data to another jurisdiction, insofar as it is necessary to fulfill the purpose for which Persona Data was collected. Your Personal Data may be transferred to the following locations:

• Countries where our corporate offices are located;
• Countries in which we manage and operate outlets, and/or sales offices; and
• Countries where our third-party service providers, advisors, and consultants are located, which changes from time to time.

Where Personal Data is transferred to a country with a lower level of data protection as compared to the country in which the information was collected, we take all reasonable steps to ensure that your information and privacy are protected in line with the applicable legal obligations. Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use data processing contractual clauses that provide sufficient protection measures and enable the enforcement of the data subject’s rights.
• Minor Group could use the consent of the data subjects as well as any other legal basis that the applicable law provides.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements of the applicable country.

Minor Group would like to inform you about the following retention period:

• Your personal data involved in the processing under lawful grounds the contractual relationship will be stored for the entire duration of the contractual relationship and once it has ended until the responsibilities for both parties expire.
• Your personal data involved in the processing under lawful grounds of legal obligation, will be stored until the completion of this obligation.
• Your personal data involved in the processing under lawful grounds of legitimate interest, will be stored until the end of this interest.
• Your personal data involved in the processing under lawful grounds of consent, will be until this consent is withdrawn. In the case of communications, you may opt-out through the means provided in each of these communications.

Details of retention periods for different aspects of your personal data are available in our Retention Statement which you can request by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. If you want us to establish the data’s accuracy
2. Where our use of the data is unlawful, but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you no longer want to receive marketing-related emails, you may opt out by visiting our [unsubscribe page] or by following the instructions in any email you receive from us.

Contact Us

If you wish to exercise any of the rights set out above, please contact us.

Under certain circumstances where applicable law permits, you also have the right to lodge a complaint with a competent data protection supervisory authority.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances and we will indicate the reason for refusal.

Time limit to respond

We try to respond to all legitimate requests within one month or within the timeframe as specified by the applicable data protection legislation. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). These collect information that tells us how you use our website and web-related services. We use these to compile statistical reports on website activity.

This helps us make our website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognize you if you visit our website again.

You can choose to refuse cookies or set your browser to let you know each time a website tries to set a cookie. For further information on cookies, visit www.aboutcookies.org or www.allaboutcookies.org where you can also find information on how to turn them off.

The type of cookies we use on this site include:

Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Analytics Cookies: We use these cookies to analyse and identify the behaviour of our web visitors. We will track the IP address on the device you are using to identify you when visiting our website. When possible, we combine your online web behaviour data with the personal data that you have previously supplied to us. This data will be used to analyse behaviour on our website and to personalise your experience.

If you wish to block the cookies please visit:

• Google AdWords – https://adssettings.google.com/authenticated
• Facebook Pixel – You may disable any of these cookies or similar technologies via your browser settings.
• Twitter Advertising – You may disable tailored advertisements via your Twitter settings by visiting the “Promoted content” and “Personalization” sections.
• Google Analytics – You may disable any of these cookies via your browser settings or by downloading a browser add-in: https://tools.google.com/dlpage/gaoptout.

You may disable any of these cookies via your browser settings.

You guarantee that you have informed any third parties whose data you are providing, if you have done so, of the points covered in this Privacy Statement. In addition, you guarantee that their authorization has been obtained to provide their data to Minor Group for the indicated purposes.

You will be liable for any false or inaccurate information provided and for direct or indirect damage caused to Minor Group or to third parties.

We keep our Privacy Statement under regular review. At the top of this page you will see the date on which the Privacy Statement was last revised, and it is also the date from which any changes will become effective. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at privacy.corporate@minor.com.

It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.