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Privacy Notice


For Business Partners

BSL Clinic Co., Ltd. (the “Company”) respects and values the privacy rights concerning the personal data of its business partners, prospective business partners, who may be natural persons or representatives of juristic persons, such as directors, authorized signatories, proxies, sub-proxies, operators, agents, employees, and staff of juristic persons that have entered into or are expected to enter into transactions with the Company (“you”).

The Company is responsible for maintaining the security of your personal data under its supervision and is committed to managing such data in a secure and reliable manner. For this reason, the Company has prepared this Privacy Notice for Business Partners (the “Notice”) to explain how the Company handles personal data and sensitive personal data, and to provide details regarding the collection, use, disclosure, and purposes of processing personal data, as well as to inform you of your rights, as follows:


1. Definitions

“Prospective Business Partner”means any person who may become a business partner of the Company, whether such person has expressed an intention to enter into a contract and/or to register as a business partner of the Company, shown interest in engaging in business with the Company, cooperated with the Company, or any other person who has requested a quotation or to whom the Company has provided a quotation.
“Business Partner”means any person who submits a quotation to sell products and/or provide services to the Company, business alliances, business collaborators (whether selling products directly to the Company or jointly developing products with the Company for sale), service providers, service recipients, employers, contractors, consultants, specialists, academics, lecturers, or contractual parties of the Company.
“Related Person”means a natural person who is related to or represents a Prospective Business Partner or a Business Partner, such as directors, employees, agents, proxies, principals, witnesses, or persons acting on behalf of a juristic person. It also includes individuals whose personal data appears in documents related to the contractual process, such as shippers or consignees.
“Personal Data”means any information relating to an individual that enables the identification of such individual, whether directly or indirectly, but does not include information of deceased persons specifically.
“Sensitive Personal Data”means personal data concerning race, ethnicity, political opinions, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, biometric data, or any other information that may similarly affect the data subject, as prescribed by the Personal Data Protection Committee.

2. Categories and Sources of Personal Data

The Company collects your data by directly requesting information from you, which may be in the form of documents or electronic data, by asking you to fill in information on documents prepared by the Company, or to fill in information on an online platform designated by the Company, and/or by any other methods. The Company needs to process certain data of yours, which may be data that the Company receives from sources other than directly from you. The personal data collected from you may vary depending on the case and the nature of the activities for which the Company is required to process your data.

General personal data: personal details such as title, name, surname, identification card number, nationality, signature, residential address, telephone number, fax number, email, information on business cards such as occupation, job position, workplace, interaction and communication data in the case where you contact the Company, including the data you choose to share and disclose through the Company’s systems, applications, tools, questionnaires, and services, in any form or by any method, which may be images or voice, not limited to telephone, email, chat messages, and social media communications.

Data identifying the status as a business representative, guarantor, collateral provider, status as an executive, director, authorized signatory, shareholder, proxy, sub-proxy, operator, agent, employee, and staff of juristic persons who have entered into or will enter into transactions with the Company. Data used as supporting evidence for registration as a business partner with the Company or for conducting transactions, such as personal data appearing in a copy of the identification card, copy of the name change certificate, copy of the house registration, copy of the power of attorney, copy of the company certificate, invoice, receipt, payment voucher, including any other documents used for identification and verification. Other personal data that you have provided to the Company, such as other personal data of Related Persons, for which you certify to the Company that you have obtained the consent of the Related Persons to disclose their data to the Company, including their consent for the Company to process their personal data for the purposes specified in this Notice.


3. Sensitive Personal Data

The Company has no intention to collect, gather, use, or disclose your sensitive personal data. However, if such data appears on the identification card, house registration, or any other documents that you voluntarily disclose to the Company, such as race or religious data, and you deliver any data containing such information to the Company, whether in the form of documents or other media, the Company recommends that you conceal such sensitive personal data yourself by crossing out the sensitive personal data. Nevertheless, if you do not conceal the data by yourself, the Company shall deem that you have explicitly granted permission for the Company to conceal such data on your behalf, and the data you deliver, which the Company has concealed on your behalf, shall be considered as complete documents, fully enforceable under the law, and the Company shall be able to process them under the Personal Data Protection Act B.E. 2562 (2019). In the event that the Company is unable to conceal sensitive data on your behalf due to technical issues or other problems, the Company shall store such sensitive data only as part of your identification documents.

In the case that the Company receives your personal data from third parties, clients of the Company, and/or any other persons who are controllers or processors of the data, which the Company in good faith believes that such persons are entitled to process and disclose personal data to the Company, this includes but is not limited to receiving data through the following channels:

  • 3.1 The Company may receive your personal data from external parties, such as collecting personal data through intermediaries, or in some cases, the Company may collect your personal data from public sources, sources relating to your business, or commercial sources, etc.
  • 3.2 Officers and authorized agencies under the law, such as the Department of Business Development, Ministry of Commerce, the Office of the Securities and Exchange Commission, and the Stock Exchange of Thailand.
  • 3.3 Other third parties, such as the company with which you are affiliated, your representatives, employers, sponsors, and third parties who play a role in providing services to you, distributors, external agents, including any persons acting on behalf of such persons.

4. Purposes and Legal Bases for Processing Data

  • 4.1 The Company processes your data in cases where you are required to provide personal data for the performance of a contract and/or compliance with relevant laws, and under legitimate purposes for the performance of a contract between you and the Company. If you do not wish to provide such personal data to the Company, it may result in legal consequences or may cause the Company to be unable to perform its obligations under the contract entered into with you, or unable to enter into a contract with you (as the case may be). In such cases, the Company may be required to refuse to enter into a contract with you or to refuse to provide benefits related to you, in whole or in part.
  • 4.2 The Company may rely on or refer to (1) the consent basis for processing your data, (2) the contractual basis for initiating a contract, entering into a contract, or performing a contract with you, (3) the legal obligation basis for the Company, (4) the legitimate interest basis of the Company and third parties, (5) the vital interest basis for preventing or suppressing danger to a person’s life, body, or health, and/or (6) the public interest basis for carrying out missions for the public interest or performing duties in the exercise of state authority, or other legal bases as prescribed under the Personal Data Protection law, as the case may be. Under this Notice, the Company will process your personal data in accordance with the following purposes and legal bases:
No.PurposeLegal Basis
1To carry out your requests or intentions prior to or at the time of entering into a contract, including contacting you before you enter into a contract with the Company, and to take any actions for the Company’s business continuity, such as suitability assessments, qualifications, claims, quotations, and bidding.Performance of a contract / Legitimate interest
2To manage and administer the contracts that the Company has entered into or will enter into with you, including inspection and acceptance of goods or services, relationship management, inspection and evaluation of performance in accordance with the terms specified in purchase orders, contracts, or other documents related to the procurement process.Performance of a contract / Legitimate interest
3To carry out processing in relation to requests, approvals, contract execution, use of electronic transaction services, verification and authentication in the process of vendor registration, including contract relationship management between you and the Company, and all matters related to contract signing and performance.Performance of a contract / Legitimate interest
4For procurement, vendor selection, registration of new vendors, verification of vendor information and qualifications, or of related persons in similar capacities, as well as carrying out various requests of vendors or other persons in similar capacities within the Company’s system, such as modification or amendment of vendor information.Performance of a contract / Legitimate interest
5For the retention, updating, and maintenance of names, directories, and records of any business transactions between the Company and business partners, as well as for storing contracts and related documents in the Company’s records.Legitimate interest
6For billing or collecting debts owed to the Company, conducting transactions, making and/or receiving payments, handling claims and disputes, including dispute resolution, establishing legal claims, complying with or exercising legal claims, or raising defenses against the Company’s claims at various legal stages, as well as conducting legal proceedings and enforcement actions under the law.Performance of a contract / Legitimate interest
7For the management of the Company’s structure, data storage for report preparation, internal control, business operations, and compliance with the Company’s policies and procedures, which includes risk management, security, auditing, finance and accounting, systems, and operations for the Company’s business continuity.Legitimate interest
8For use in transfers, mergers, business reorganizations, or similar events, whereby the Company may disclose or transfer your personal data to one or more third parties involved in such transactions.Legitimate interest
9To carry out the completion of transactions, debt establishment, payments, account settlements, accounting entries, and verification of account numbers and credit or debit card numbers, as well as transactions related to payments, refunds, issuance of receipts, invoices, debt repayments, collections, and any other actions related to your account as a business partner of the Company.Performance of a contract / Legitimate interest
10For the Company’s business administration in monitoring, preventing, identifying, and investigating fraud, money laundering, terrorism, misconduct, or other criminal activities, including but not limited to conducting credibility checks on any persons related to the Company’s business partners.Legitimate interest
11To serve as a database for analysis, preparation of activities, performance under contracts, and to carry out matters relating to contract management or entering into additional contracts in the future.Performance of a contract / Legitimate interest
12To serve as a database of the Company’s stakeholders and/or to use the data for relationship management or for various communications related to the Company and you.Legitimate interest
13To comply with applicable laws, regulations, and rules, both domestic and international, and to comply with orders of legally authorized persons, such as court orders, orders of government agencies, regulators of the Company, or competent officers, including actions related to legal processes or litigation.Compliance with the Law
14For use in issuing tax invoices in accordance with the Revenue Code and other applicable laws or announcements, such as Section 86/4 of the Revenue Code and the Director-General of the Revenue Department’s Notification on Value Added Tax (No. 199), etc.Contractual Performance/Compliance with the Law

5. Disclosure of Personal Data

  • 5.1 The Company may disclose your personal data under the specified purposes and in accordance with the law to the following persons and entities:
    • 5.1.1 Affiliated companies and other related companies as listed on the website www.bslclinic.com with which joint agreements exist. This shall include the executives, directors, employees, staff, and/or internal personnel of such companies, insofar as relevant and necessary for the processing of your personal data.
    • 5.1.2 Service providers and personal data processors assigned or engaged by the Company to manage or process personal data on behalf of the Company in providing services, including those acting in the name of or in collaboration with the Company to carry out related purposes as specified in this Notice, and who necessarily require access to your personal data, such as providers of information technology services, data recording services, payment services, auditing services, or any other services that may benefit you or relate to the Company’s business, where it is reasonably necessary to disclose your personal data in order to achieve the Company’s business objectives.
    • 5.1.3 The Company’s advisors, such as legal advisors, lawyers, auditors, accountants, or other experts, both internal and external to the Company.
    • 5.1.4 Government agencies with regulatory authority under the law, or those requesting disclosure of personal data by legal authority, or those involved in legal processes, or authorized under applicable laws, such as the Revenue Department, Social Security Office, Department of Labour Protection and Welfare, Department of Provincial Administration, Department of Business Development, Department of Intellectual Property, Office of the Personal Data Protection Committee, Office of Trade Competition Commission, Royal Thai Police, Office of the Attorney General, Courts, and the Legal Execution Department, etc.
    • 5.1.5 Transferees of any rights, duties, and benefits from the Company, including those authorized by such transferees to act on their behalf, such as in cases of corporate restructuring, mergers, or acquisitions.
  • 5.2 The Company shall require the recipients of the data to implement appropriate measures to protect your data and to process such personal data only to the extent necessary, and shall act to prevent unauthorized use or disclosure of personal data. The Company shall act only under the purposes specified in this Notice or other purposes permitted by law. In cases where the law requires your consent, the Company will obtain your consent before proceeding.

6. Transfer or Transfer of Personal Data to Abroad

The Company may store your data on computer servers or cloud services provided by third parties and may use third-party programs or applications in the form of software-as-a-service or platform-as-a-service for processing your personal data. However, the Company will not allow unrelated persons to access personal data and will require such third parties to have appropriate security protection measures in place.

In the event that the Company transfers or sends your personal data abroad, the Company will take steps to ensure that the destination country, international organization, or foreign data recipient has an adequate standard of personal data protection or to ensure that the transfer or transmission of your personal data abroad complies with the criteria prescribed under the Personal Data Protection law. In some cases, the Company may seek your consent for the transfer or transmission of your personal data to such foreign countries.


7. Retention Period of Personal Data

  • 7.1 The Company will retain personal data only as necessary for the purposes of processing as specified in this Notice, divided as follows:

In cases where you provide information to the Company as a contracting party, business partner, prospective business partner, or a related person thereof, the Company will retain your data as long as necessary to provide services to you for the duration of the contract, and will retain it for an additional five (5) years from the year the contract or relationship with you ends.

In cases where rights requests are made as specified in this Notice, the Company will retain evidence of the exercise of such rights under the Personal Data Protection law for five (5) years from the month in which the Company completes consideration of your request.

In other cases, the Company will retain your personal data as long as reasonably necessary to fulfill the Company’s obligations and achieve the purposes specified in this Notice. Where the retention period cannot be clearly determined, the Company will retain the data for a period that may be reasonably expected under standard practices (e.g., the maximum statute of limitations under general law, which is ten years). In the event of legal proceedings, your personal data may be retained until the completion of such proceedings, including any period necessary to achieve the intended purposes. Thereafter, your data will be deleted or retained only as permitted by law.

  • 7.2 Upon the expiration of the retention period, the Company will delete, destroy, render the personal data non-identifiable, or take any other actions as prescribed by the Personal Data Protection law to ensure effective protection of personal data. However, the Company will retain certain data for longer than the period specified above if required to comply with laws, orders of competent officers or government authorities, and for business purposes or legitimate grounds.

8. Rights of Data Subjects

The Company respects your privacy rights and allows you to choose the methods of control or the means by which the Company contacts you. The Company will comply with your requests in order to promote transparency, and ensure the quality and accuracy of data. You have rights under the Personal Data Protection law, which you can exercise by submitting a written request to the Company through the channels specified by the Company, as follows:

  • 8.1 Right to Withdraw Consent: If you have given consent for the processing of your personal data (whether the consent was given before or after the Personal Data Protection law came into force), you have the right to withdraw such consent at any time while your personal data is with the Company.

However, please be informed that the withdrawal of consent does not affect the lawful processing of personal data that you have already consented to, unless such right is restricted by law, by nature cannot be withdrawn, or where there is a contract between you and the Company that provides benefits to you, or such withdrawal may result in the Company being unable to carry out certain or all purposes as specified in this document.

  • 8.2 Right of Access: You have the right to access your personal data under the responsibility of the Company and to request the Company to provide you with a copy of such data, as well as to request the Company to disclose how your personal data has been obtained, except where the Company has the right to refuse your request as permitted by law, court order, or where fulfilling your request may cause damage to the rights and freedoms of others.
  • 8.3 Right to Data Portability: You have the right to request the transfer of your personal data in cases where the Company has prepared the personal data in a format that is readable or usable by automated tools or devices and can be used or disclosed by automated means. You also have the right to request the Company to send or transfer such personal data to another data controller, where possible by automated means, and to request the Company to directly transmit such personal data to another data controller, except where it cannot be done due to technical reasons.

Such personal data must be data that you have consented to provide to the Company, or personal data that the Company needs to process to allow you to use the Company’s services as intended under your contract with the Company, or to carry out your requests prior to service use, or other personal data as prescribed by the competent legal authority.

  • 8.4 Right to Object: You have the right to object to the processing of your personal data at any time, if such processing is carried out for operations necessary under the legitimate interests of the Company or other persons or juristic persons, within a scope reasonably expected by you, or for carrying out missions in the public interest, or for scientific or statistical research purposes.

If you object, the Company will continue processing your personal data only where it can demonstrate legal reasons that are more significant than your fundamental rights, or where it is for the establishment of legal claims, compliance with the law, or defense in legal proceedings, as the case may be.

  • 8.5 Right to Erasure or Destruction: You have the right to request the erasure or destruction of your personal data, or to make the data non-identifiable, if you believe that your personal data has been unlawfully processed, or if you consider that the Company no longer needs to retain it for the purposes stated in this Notice, or when the Company deems it possible to comply with your request to withdraw consent or exercise your right to object as mentioned above.
  • 8.6 Right to Restriction of Processing: You have the right to request the temporary suspension of the use of your personal data where the Company is in the process of verifying your request to rectify personal data or your objection, or in other cases where the Company no longer needs to retain or must erase or destroy your personal data under relevant law, but you request the Company to suspend the use of such personal data instead.
  • 8.7 Right to Rectification: You have the right to request the rectification of your personal data to be accurate, up to date, complete, and not misleading. In case you wish to request the correction of image-related data, the Company will rectify only the information related to your images to be accurate as necessary and lawful for the Company. In cases where complying with your request incurs expenses, the Company may charge you for such expenses.
  • 8.8 Right to Lodge a Complaint: You have the right to lodge a complaint with the Company through the Data Processing Complaint Form, or with the competent legal authority, if you believe that the processing of your personal data is conducted in a manner that violates or does not comply with applicable laws.

9. Methods for Exercising Data Subject Rights

The Company will use its best efforts to proceed within a reasonable period of time and not exceeding one (1) month or 30 business days from the date of receipt of the request. However, the Company has the right to refuse your request in cases where there are legal exceptions, or where the Company would be unable to perform its contractual obligations, or where it would affect the performance of contractual obligations, or where refusal is based on a court order, or if complying with your request would result in impacts that may cause damage to the rights and freedoms of other persons. In such cases, the Company will record the refusal of the request together with the reasons.

If it is clearly apparent that your request is unreasonable or excessive, the Company reserves the right to charge a fee for processing your request at the rate determined by the Company.

  • 9.2 The Company will make every effort within the capability of the relevant systems to facilitate and comply with your request, unless it is evident that fulfilling the request poses a risk of violating the rights and freedoms of other users, or is contrary to the law or system security policies, or where compliance with the request is impracticable due to technical reasons.
  • 9.3 In some situations, the Company may require you to verify your identity before exercising your rights for your own security. In certain cases, there may be limitations to the exercise of your rights, which the Company will explain to you if it cannot comply with your request.
  • 9.4 If the Company processes your personal data on the basis of contract performance, legitimate interest, or legal obligations, the Company has the right to refuse your exercise of rights in cases where you object, request restriction of use, or request the deletion or destruction of your personal data. The Company may also refuse to comply with your request if it is necessary for the Company to continue retaining the data.
  • 9.5 The Company must inform you that certain rights requests may be subject to limitations in cases where such personal data is strictly necessary for the Company to comply with legal obligations and for maintaining the security of the Company, its surrounding premises, the security of activities, and your own safety.

10. Security Measures

The Company has implemented appropriate personal data security measures to prevent loss, access, use, alteration, modification, or disclosure of personal data without authorization or in violation of the law, in accordance with the Company’s Information Security Policies and Practices and the Privacy Policy.


11. Contact Channels of the Company

Bangkok Skin and Laser Clinic Co., Ltd. is the coordinator regarding the Company’s personal data protection. In case the data subject has any questions, wishes to exercise rights as specified in this Notice, or seeks further inquiries, contact can be made through the following channel:

Matters related to personal data: Contact the Data Protection Officer (DPO)

  • Email: [email protected] and complete the form via the Link
  • Address: 30/8 Saladaeng Road, Silom Subdistrict, Bangrak District, Bangkok 10500
  • Telephone: 099-343-8666
  • Business hours: Daily, 10:00 a.m. – 8:00 p.m.

12. Amendments

The Company reserves the right to amend, review, and update this Privacy Notice, which shall be effective as of the date of publication without prior notice to you, in order to ensure appropriateness and efficiency in providing services. Therefore, the Company recommends that you read this Privacy Notice each time you visit or use the Company’s services or website.

Announced on May 31, 2022