Southeast Insurance Public Company Limited (the “Company,” “we,” “us” or “our”) values the continued trust and confidence given to us by our customers, insured persons, beneficiaries under non-life insurance policies and users of our non-life insurance products and other services, as data subjects, for us to collect, use, process or otherwise handle their Personal Data, for the purpose of providing and developing our various services. As the privacy of data subjects is our utmost priority, we strongly believe that it is our responsibility to collect, use, process and/or disclose Personal Data only for the purposes permitted by data subjects, and to protect the Personal Data in our possession and keep it in strict confidence.

To this end, in order to allow you, as our customers, users of our services, trading partners and contracting parties, who are data subjects, to understand our procedures and practices with respect to the collection, use, processing and/or disclosure of Personal Data, and thus trust our operations involving the collection, use, processing and/or disclosure of Personal Data, and to ensure you that our operations adhere to good governance principles and strictly comply with the law on personal data protection and other applicable laws, we have developed this Personal Data Protection Policy, in accordance with the law on personal data protection and other applicable laws.

This Personal Data Protection Policy was approved by the Board of Directors, at Meeting No. 8/2562, on 12 November 2019. Details of the Policy are set out below.

Order No. BOR KOR. 099/01/2560 Re: Personal Data Protection Policy, announced on 18 August 2017, shall be repealed and replaced by this Notification.

1. Definition

2. General Details

This Personal Data Protection Policy has been developed to provide details of the Company’s operations involving the handling of your Personal Data. We may update or revise this present Personal Data Protection Policy, or the Personal Data Protection Policy as available on any particular part of our website, application, application form or any document, whether in whole or in part, without prior notice, to reflect changes in our practices, rules and/or laws. Therefore, we encourage you to periodically review this Policy in order to keep updated. We will publish our revisions to this Policy on our website, and we will inform you when material changes are made.

This Personal Data Protection Policy applies to any Personal Data that you provide to us when you register or apply for our services, apply for our non-life insurance products or other services, enter into an agreement with us as a trading partner or contracting party, access and/or use any content on our electronic systems, websites or applications, whether they are available now or will be developed or made available in the future.

This Personal Data Protection Policy should be read in conjunction with other relevant documents, such as the Consent Form that we send to you for your consideration when we would like to collect your Personal Data, so that you understand and are informed of how we handle your Personal Data.

3. Purposes for the Collection, Use and Processing of Personal Data

• 3.1To allow us to develop and/or provide you with non-life insurance products, as well as other services, that are appropriate and suitable for your needs;

• 3.2For our consideration as to whether to provide services to you under the terms and conditions of a particular non-life insurance product, or the relevant terms of service;

  (Please note that we may, with your express consent, collect Personal Data relating to you from other reliable sources. In addition, we may request other Personal Data, such as your health information, information pertaining to race, criminal record, financial record, genetic information, biometric data, etc., only to the extent that it is necessary for our consideration for approval of any contract that relates to a particular non-life insurance product, other agreements that we are a contracting party with you, or the provision of services, as mentioned in this Clause.)

• 3.3 For our consideration of an insurance application form or any request concerning a non-life insurance contract for the execution of an insurance contract and/or change of Personal Data in response to your request, including the collection, use and processing of Personal Data for the purpose of and in reference to the provision of services per your request;

• 3.4For our consideration of compensation payment under the Company’s or a healthcare facility’s insurance contract for your benefits (We may, with your express consent and upon request, disclose and transfer your Personal Data to a healthcare facility abroad, only to the extent that it is necessary for your medical treatment.);

• 3.5For our risk assessment and management, and/or for our reinsurance, in accordance with the rules and methods set out in the Office of Insurance Commission’s Notifications and/or our predetermined reinsurance policies;

• 3.6To facilitate payment of insurance premiums or any other payments invoiced to you by us and/or our financial service providers;

• 3.7In cases where you choose to pay insurance premiums through a debit or credit card, or a direct debit from a bank account, and you have informed our staff member, employee, non-life insurance agent or broker of your intended payment method, or you have selected your intended payment method on our application, to enable your credit or debit card issuer or the relevant financial institution to collect and process your insurance premium payments or other service charges payable to us by you;

• 3.8To manage any debt obligations that we owe to you, or that you owe to us, and to collect and demand any amounts payable to us by you or any person who has provided any security, or has otherwise agreed to be liable, for your liabilities with us;

• 3.9For any purposes, without limitations, in connection with any claims or complaints from or against you, or otherwise in connection with the provision of our services and/or products to you, for our consideration of objections, analysis, investigations, proceedings, assessments, determinations, responses, resolutions or agreements with respect to such claims or complaints;

• 3.10For our consideration as to whether to enter into a business partnership agreement, such as a non-life insurance agency or brokerage agreement, business cooperation agreement or an agreement for sales promotional activities, and for any actions necessary for the performance of said agreement;

• 3.11To ensure that your use of our services goes smoothly and corresponds with any applicable laws, rules and regulations, and for our compliance with any obligations under the relevant or applicable laws and rules, including but not limited to laws on non-life insurance, computer crimes, personal data protection or any other relevant laws, as they are effective now or may be amended in the future;

• 3.12For our communication with you via telephone, SMS, email, mail or any channels, for delivery of documents, inquiries or notification, examination and verification of your account information, surveys or notification of any news or information concerning the provision of our services, as necessary; and

• 3.13For our legitimate business interests, or for legitimate business interests of our parent company, any of our subsidiaries, partners or affiliates, any of the companies that control us or under our common control, or any of our business partners or trading partners; for the purpose of conducting studies, research or statistics; for the purpose of improving our services and conducting marketing or targeted advertising; for the purpose of related business operations; and for the purpose of delivering news and information about our activities and promotions and recommending non-life insurance products and other appropriate services according to your interest.

Please note that when you contact us, or our staff, we may record our conversation, or otherwise record details of said communication. Your continued communication with us, or our staff, shall be deemed to be your acknowledgment and consent for the audio recording of the conversation and/or details of such communication.

In cases where it is necessary for us to use your Personal Data for any purpose other than those specified above, we will inform you of such new purpose, together with other necessary information, to obtain your consent again.

4. Information and Data, and Collection and Use thereof

We collect your Personal Data only when you have given us express consent in writing, or through electronic means, including the collection of data through technologies such as cookies, which are small text files stored on your computer that allow our website to remember your access or use of our website each time. Information and data relating to you that we collect includes the following:

• 4.1 Information that you give to us directly

  We collect the Personal Data that you give to us, such as the information included in your insurance application form or other service application form, the information included in your application for entering into a contract with us, any information about your participation in activities on our websites or applications, information gathered from surveys that you participate in, your user account data and revised data, information that we receive from you, or from our employees, non-life insurance agents or brokers, trading partners or contracting parties, information that we receive because you contact us through any of our Information Systems, or information that we receive from other user accounts and we reasonably know that such information relates to you, which includes but is not limited to all types of information collected from you, such as your name and surname, address, date of birth, gender, age, photograph, email address, bank account number (if applicable), credit card number (if applicable), ID Card number, passport number, taxpayer identification number, telephone number, health record, criminal record, fraud record, your interest and opinions given on our website (if any) or any other channels provided by the Company. We will keep the Personal Data relating to you that we collect in your account.

• 4.2 Data obtained from your use of services

  We collect data about your use of our services and the nature of your use of our services, including but not limited to data about the device that you use to access our website, log data, your communication with other users, usage record data, such as your unique device identifier, IP address, device ID, the type of your device, mobile phone network, connection data, GPS data, the type of your browser, transaction logs, customer behavior, usage statistics, access time, your search, your use of our website functions and any data that we collect through cookies or similar technologies.

  The above is only a sample list of the information and data that we may collect. We will collect only the Personal Data that is necessary, and will retain it only for as long as it is needed for our performance of the relevant contract, such as a contract for an insurance product or insurance services, or a financial contract, or for our performance of legal obligations that relate to you or the provision of our services to you, as the case may be, and for the purposes originally specified.

  Please note that in cases where we need to collect your Personal Data because of legal requirements or obligations or contractual requirements that we have with you and you do not provide us with the Personal Data that we need, we may not be able to perform our obligations or the contractual requirements that we have with you. For example, we may not be able to provide services or distribute our products to you. In such event, we may need to cancel the provision of services or the distribution of products to you, in which case we will inform you of such consequences in advance.

5. Disclosure of Personal Data to Third Parties

We will not disclose your Personal Data to any third party without your express consent, except where your consent is not required under the law. Please note that for the purpose of providing our services to you, we may need to disclose your Personal Data to our subsidiaries, parent company, partners, affiliated companies, business partners, third-party service providers, data processors, prospective or actual claim assignees, duly authorized persons, or any persons, whether in Thailand or abroad, who are our contracting parties, such as the persons retained by us to provide services regarding Personal Data, in order for us to use your Personal Data to improve our insurance products and services for you, improve how we provide our services on our website and the access to our website content, or to maintain the security of our website and networks, or for the purpose of carrying out our operations (collectively, “Recipient”). In cases where we obtain your consent for disclosure of Personal Data to these persons, we will arrange for the collection, use and/or disclosure of your Personal Data by these persons only for the specified purposes for which we have obtained your consent, and we will ensure that your Personal Data will be kept confidential and will not be used for any purposes other than those for which we have obtained your consent.

In cases where we need to transfer your Personal Data to a Recipient in a third country where adequate personal data protection standards as determined by the Personal Data Protection Committee are implemented, we will do so in compliance with the relevant policy for the protection of Personal Data in the case of transfer of Personal Data to a Recipient abroad. Please note that such policy is subject to revisions as the relevant subordinate laws are being reviewed by the regulatory authority. We will keep you informed about any revisions.

If you find that any Recipient uses your Personal Data beyond the scope of the specified purposes, you may inform us for further action. However, we encourage you to make sure whether you have used the Recipient’s website, products or services, in which case the Recipient may have collected data due to your direct use of its website, products or services and we are not responsible for the security or privacy of any data collected accordingly. Therefore, we encourage you to exercise care and also review the Recipient’s personal data protection policy with respect to its website, products and services.

In addition, we may disclose your Personal Data under the criteria permitted by laws, such as disclosure to official or government authorities, regulatory authorities, or bodies of which we are a member, such as the Thai General Insurance Association, or upon request for legal prosecution or actions, or upon request from a private sector or third party involved in legal proceedings, or when it is necessary and appropriate for the enforcement of the terms and conditions of our services. In the case of our restructuring, merger or sale of business, we may transfer your Personal Data collected by us, whether in whole or in part, to any involved company without prior notice.

6. Access to and Rectification of Personal Data

• 6.1If you do not wish to receive news and information from us, you may inform us in writing or through our Customer Relations Center, or you may unsubscribe our news in an email that you receive from us any time.

• 6.2If you want us to suspend the use of your Personal Data, or delete, add, modify or correct your Personal Data so that it is complete, accurate and updated, you can make a request in writing through documents, such as an insurance application form, a request form for change of information, etc., or through our Customer Relations Center.

  Please note that if you request that we erase your Personal Data from our system, we may not be able to provide the services required for a particular insurance product or other services, or the services that we provide to you may not be as efficient as they would be if we had your Personal Data.

• 6.3Upon our receipt of your request concerning your Personal Data, we will make our best effort, using our existing systems and their current capacities, to facilitate and respond to your request, except where the fulfilment of your request may violate another person’s rights, any laws or our system security policy, or it is not practically possible.

  As for your request for erasure of your Personal Data from our system, we will make our best effort to respond to your request by using our existing technologies and their current capacities. However, such data may still remain in our server or backup system, which keeps copies of your data to prevent data loss due to a system failure or error, or a malicious act or software, and for use as evidence or to comply with legal requirements.

7. Your Rights as a Data Subject

• 7.1You have the right to request that we correct or change your Personal Data so that it is complete, accurate and updated.

• 7.2You have the right to withdraw your consent for the collection, use, processing and/or disclosure of your Personal Data any time, by making a written request to us or through our Customer Relations Center, email or any other channels that are available now or will be created in the future.

• 7.3You have the right to request that we suspend the collection, use or disclosure of Personal Data relating to you any time.

• 7.4You have the right to object to the collection, use and/or disclosure of Personal Data relating to you if such collection, use and/or disclosure may be carried out by us without your consent.

• 7.5You have the right to request access to, or to obtain a true copy of, Personal Data relating to you, or to request that we disclose the source of your Personal Data where we obtain it without your consent.

• 7.6You have the right to obtain a copy of the Personal Data that we hold about you, and to request that we transfer your Personal Data to another data controller or data processor, or request that we provide a copy of the Personal Data relating to you that we have transferred to another data controller or data processor.

• 7.7You have the right to request that we erase, destroy or anonymize Personal Data relating to you.

• 7.8You have the right to request that we disclose the source of Personal Data relating to you that we collected without your consent for our collection or retention.

• 7.9You have the right to file a complaint if we or our data processor, including our employees or contractors, violate or do not comply with the personal data protection law or any notifications issued by virtue thereof.

8. Secure Storage of Personal Data

We have developed and/or used a Personal Data storage system that has appropriate mechanisms and techniques, including a feature that restricts access to your Personal Data by our employees, customers and agents, in order to prevent unauthorized use, disclosure, destruction or access to your Personal Data. If we find that our employees violate your Personal Data, whether directly or indirectly, such violation will be deemed to be a material breach of our rules and the relevant persons will be subject to the penalties prescribed by the applicable law. If it is our contractor who commits such violation, we will immediately terminate our contract with such contractor.

When there is a data breach incident, we will notify such incident to the Personal Data Protection Committee within 72 hours after having become aware of it, if possible, unless such incident causes no risks to the rights and freedoms of a person. If there is a high risk of adversely affecting your rights and freedoms, we will notify you about such incident and measures to mitigate any possible adverse effects without delay, i.e., within 72 hours after having become aware of it, if possible.

Regardless, we cannot guarantee that the measures we have in place will have no defects or errors. Therefore, we hereby disclaim liabilities for any damage or loss in all cases.

9. Links to Third-Party Websites, Products and Services

Our website may contain links to third-party websites, products and services. If you voluntarily follow those links, such third parties may collect certain data concerning your use of services. In such event, we are not responsible for the security or privacy of any data collected in connection with such third-party websites, products and services. We encourage you to exercise care and also review the personal data protection policies with respect to those third-party websites, products and services.

10. Contact Us

If you wish to exercise any of the rights described in Section 7 above or should you have any inquiries, suggestions, complaints or comments regarding this Personal Data Protection Policy or our compliance with this Personal Data Protection Policy, you can contact us at the address and through the channels specified below. We are willing to respond to your inquiries and we are open to your suggestions and comments, which will help us improve our services in the future. Our contact details are as follows:

• Customer Relations Center
• Southeast Insurance Public Company Limited
• 315 Southeast Building, Silom Road, Silom,
• Bangrak, Bangkok 10500
• Tel: 1726
• Email: seiccare@segroup.co.th

11. Enforcement of this Personal Data Protection Policy

This Personal Data Protection Policy comes into effect today. It applies to all your Personal Data collected, used, processed and/or disclosed to Recipients by us, whether it was collected by us, can be collected by us based on your consent that we have obtained, will be collected in the future or was gathered from other sources (if any).

In cases where the personal data protection law and/or other relevant laws change, or where any rules, criteria, notifications and/or regulations (“Subordinate Laws”) are subsequently issued, which may affect the enforcement of this Personal Data Protection Policy, and any part of this Personal Data Protection Policy is contrary or inconsistent with the then-current personal data protection law and/or any Subordinate Laws subsequently issued, the provisions of the then-current personal data protection law or such Subordinate Laws with respect to such part shall prevail.

12. Governing Law

You acknowledge and agree that this Personal Data Protection Policy shall be governed and construed according to the Thai laws, and the Thai courts shall have jurisdiction over any disputes arising therefrom.

This Personal Data Protection Policy shall be reviewed once a year by the Board of Directors, or when there are material changes, which are made to reflect a changing situation, by our Data Protection Officer or the Data Security Department.

This Policy shall come into effect on this 15 November 2019 onwards.

What are cookies?

Cookies are small text files stored on your device (computer, smartphone, tablet or any other device that can connect to the Internet and can display our website). Cookies are used to enhance website performance and speed. Cookies often consist of site names, stored data, cookie durations and cookie identifiers.

Usage and benefits of cookies on our website

Generally, cookies are used to enhance website browsing or usage experience, and make it easier and quicker for users to use websites, by, for example, remembering setting preferences, storing login information and collecting information about visitors’ interest or behavior in order to provide custom content according to their interest. However, cookies used on our website cannot directly identify you. That is, our website does not immediately know which cookie comes from which user or device.

Cookies on our website

We use the following cookies on our website:

• Strictly necessary cookies These cookies are essential for you to browse a website and use its features. Without these cookies, websites would not be able to function. Normally, these cookies are session cookies.
• Functionality cookies These cookies allow a website to remember your setting preferences, such as your preferred language, your preferred region, weather reports, or your username and password, which will allow you to automatically log in.
• Performance cookies These cookies gather data about how visitors use a website, such as pages visited and links clicked. They do not collect identifiable data. The sole purpose of these cookies is to enhance browsing experience.
• Third party cookies These cookies may take you to third party websites, such as Google search engine and Facebook.

Changes to this Cookies Policy

We may revise this Policy as appropriate. When we make any material changes to this Policy, we will announce on our home page that these changes have been made. Therefore, we encourage you to regularly check this Policy to keep updated about these changes.