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Privacy Policy

Nawabutr Medical Center, Specialist Medical Clinic

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1. Introduction

       Nawabutr Medical Center, Specialist Medical Clinic (Hereinafter referred to in this Policy as “Nawabutr Clinic” or “Company”) realizes the importance of personal data and other information about you (collectively referred to as “Data”). In order for you to be confident that Nawabutr Clinic is transparent and responsible in collecting, using or disclosing your data in accordance with the Personal Data Protection Act B.E. 2562 (Personal Data Protection Act) and other relevant laws, this Privacy Policy (Policy) has been prepared to provide you with details on the collection, use or disclosure (collectively referred to as “Processing”) of personal data that is operated by Nawabutr Clinic, including officers and related persons acting on behalf of or on behalf of Nawabutr Clinic, with the following contents:

 

2. Scope of Policy Application

       This Policy applies to personal data of individuals who are currently and in the future related to Nawabutr Clinic, whose personal data is processed by Nawabutr Clinic, officers and contract employees. Business units or other entities operated by Nawabutr Clinic, including contractors or third parties that process personal data on behalf of or on behalf of Nawabutr Clinic (“Personal Data Processors“) under various products and services, such as websites, systems, applications, documents or other services controlled by Nawabutr Clinic (Hereinafter referred to as “Services“).

A person who has a relationship with Nawabutr Clinic under the first paragraph includes:

       1) Individual customers

       2) Officers or workers, employees

       3) Business partners and service providers who are individuals

       4) Directors, attorneys, representatives, agents, shareholders, employees or other persons who have       a similar relationship of a legal entity that has a relationship with Nawabutr Clinic

       5) Users of Nawabutr Clinic’s products or services

       6) Visitors or users of the website www.nawabutrivf.com including systems, applications, devices or other communication channels controlled by Nawabutr Clinic

       7) Other persons whose personal data is collected by Nawabutr Clinic, such as job applicants, staff families, guarantors, etc.

Sections 1) to 6) are collectively referred to as “you”.

          In addition to this Policy, Nawabutr Clinic may provide a privacy notice (“Notice”) for Nawabutr Clinic’s products or services to inform data owners who are service users about the personal data being processed, the purposes and lawful grounds for processing, the retention period of personal data, and the rights that data owners have over their personal data in specific products or services.

          In the event of any material conflict between the content of the privacy statement and this Policy, the privacy statement of that service shall apply.

 

3. Definitions

       – Nawabutr Clinic means Nawabutr Medical Center, specialist medical clinic.

       – Personal data means information about a natural person, which enables the identification of that individual directly or indirectly, but does not specifically include information about a deceased person.

       – Sensitive personal data means personal data as provided in Section 26 of the Personal Data Protection Act B.E. 2562, which includes information about race, ethnicity, political opinions, religious or philosophical beliefs, sexual behavior. Criminal records, health information, disability, trade union information, genetic information, biometric information, or any other information that affects the owner of personal data in a similar manner as announced by the Personal Data Protection Committee.

       – Personal data processing means any action taken with personal data, such as collecting, recording, copying, organizing, storing, updating, changing, using, retrieving, disclosing, forwarding, publishing, transferring, merging, deleting, destroying, etc.

       – Personal data owner means a natural person who is the owner of personal data that Nawabutr Clinic collects, uses, or discloses.

       – Personal data controller means a person or juristic person who has the authority to make decisions regarding the collection, use, or disclosure of personal data.

       – Personal data processor means a person or juristic person who performs actions related to the collection, use, or disclosure of personal data in accordance with the instructions or on behalf of the personal data controller. However, the person or juristic person who performs such actions is not a personal data controller.

 

4. Sources of personal data collected by Nawabutr Clinic

       Nawabutr Clinic collects or obtains various types of personal data from the following sources:

       4.1) Personal data that Nawabutr Clinic collects directly from the owner of the personal data through various service channels, such as the application process, registration, job application, signing contracts, documents, completing surveys or using products, services or other service channels controlled by Nawabutr Clinic, or when the owner of the personal data contacts Nawabutr Clinic at the office or through other contact channels controlled by Nawabutr Clinic, etc.

       4.2) Data that Nawabutr Clinic collects from the owner of the personal data accessing the website, products or other services under the contract or mission, such as tracking the behavior of the user of the website, products or services of Nawabutr Clinic by using cookies or from software on the owner of the personal data’s device, etc.

       4.3) Personal data that Nawabutr Clinic collects from sources other than the owner of the personal data, where such sources have the authority, have legal reasons or have received consent from the owner of the personal data to disclose the data to Nawabutr Clinic, such as linking services to the owner of the personal data themselves. Notification of personal data to government agencies as Nawabutr Clinic has a duty under the mission to provide information, including from the necessity to provide services under the contract that may exchange personal data with the contracting agency.

          This also means the case where you provide personal data of an external person to Nawabutr Clinic as follows: You are responsible for informing such person of the details according to this policy or the announcement of the product or service, as the case may be, and requesting consent from such person if it is a case that consent is required to disclose information to Nawabutr Clinic.

          In the case that the owner of personal data refuses to provide information necessary for the service of Nawabutr Clinic, it may result in Nawabutr Clinic being unable to provide such service to the owner of such personal data, in whole or in part.

 

5. Legal basis for collecting personal data

       Nawabutr Clinic considers determining the legal basis for collecting your personal data as appropriate and in the context of the service. The legal basis for collecting personal data that Nawabutr Clinic uses includes:

 

Legal basis for data collection

Details

To carry out the missions according to the missions that Nawabutr Clinic has received.

To enable Nawabutr Clinic to exercise state power and carry out its missions in accordance with the Nawabutr Clinic mission, which is stipulated by law, such as the Committee for the Protection of Children Born Using Assisted Reproductive Technology, including related rules, regulations, orders and resolutions, etc.

To perform duties in accordance with the law.

To enable Nawabutr Clinic to comply with the laws governing it, such as:

Personal Data Protection Act B.E. 2562

Protection of Children Born from Assisted Reproductive Technology Act

including compliance with court orders, etc.

It is necessary for legitimate interests.

For the legitimate interests of Nawabutr Clinic and others, which are no less important than the fundamental rights of the data subject in personal data, such as maintaining the security of Nawabutr Clinic’s premises or processing personal data for the organization’s internal affairs, etc.

It is necessary to prevent or suppress danger to life, body or health of a person.

To prevent or suppress danger to life, body or health of a person.

For the performance of the contract.

To enable Nawabutr Clinic to perform its duties under the contract or to perform any necessary actions for entering into a contract to which you are a party, such as hiring, hiring for work, making a memorandum of understanding or other forms of contract, etc.

For the preparation of important documents or statistics.

To enable Nawabutr Clinic to prepare or support the preparation of documents or statistics as Nawabutr Clinic may be assigned, such as preparing pregnancy statistics to send information to the Health Promotion Foundation, etc.

Your consent.

Your consent for the collection, use or disclosure of personal data in cases where Nawabutr Clinic is required to obtain your consent by having been informed of the purpose of the collection, use or disclosure of personal data before requesting consent, such as collecting sensitive personal data for purposes that do not comply with the exceptions of Section 24 or 26 of the Personal Data Protection Act B.E. 2562 or presenting or publicizing products and services of a contractor or business partner to you, etc.

          In the event that Nawabutr Clinic needs to collect your personal data for the performance of a contract, the performance of legal duties or the necessity of entering into a contract, if you refuse to provide personal data or object to the processing according to the purpose of the activity, it may result in Nawabutr Clinic being unable to perform or provide the services you request, in whole or in part.

6. Types of personal data collected by Nawabutr Clinic

       Nawabutr Clinic may collect or obtain the following information, which may include your personal data, depending on the services you use or the context of your relationship with Nawabutr Clinic, including other considerations affecting the collection of personal data. The types of data specified below are only a general framework for Nawabutr Clinic’s collection of personal data. However, only information related to the products or services you use or have a relationship with will be applicable.

Types of personal data

Details and examples

Personal Information.

Information indicating your nickname or information from official documents that identify you personally, such as title, first name, last name, middle name, nickname, signature, ID card number, nationality, driver’s license number, passport number, house registration information, business license number, professional license number (for each occupation), insured person identification number, social security number, etc.

Information about personal characteristics.

Personal details such as date of birth, gender, height, weight, age, marital status, military service status, photograph, spoken language, behavioral information, preferences, information on bankruptcy, information on being disabled or quasi-disabled, etc.

Contact information.

Contact information for you, such as home telephone number, mobile telephone number, fax number, email, home mailing address, social media usernames (Line ID, MS Teams), accommodation location map, etc.

Information about work and education.

Employment details, including work history and education history, such as employment type, occupation, rank, position, duties, expertise, work permit status, reference information, taxpayer identification number, job position history, work history, salary information, start date, end date, evaluation results, welfare and benefits, materials in the worker’s possession, achievements, bank account numbers, educational institutions, educational qualifications, educational results, graduation date, etc.

Insurance Policy Information.

Details of workers’ compensation insurance policies, such as insurer, insured, beneficiary, policy number, policy type, coverage amount, claim information, etc.

Information about social relationships.

Your social relationship information, such as political status, political positions, directorships, relationships with Nawabutr Clinic staff, contractual information with the organization, stakeholder information in business dealings with the organization, etc.

Information about using the services of Nawabutr Clinic.

Details regarding products or services of Nawabutr Clinic, such as username, password, PIN number, Single Sign-on (SSO ID) information, OTP code, computer traffic information, location information, photographs, videos, audio recordings, usage behavior information (websites under the care of Nawabutr Clinic, such as www.nawabutrivf.com or various applications), browsing history, cookies or similar technologies, device number (Device ID), device type, connection details, browser information, language used, operating system used, etc.

Sensitive personal data.

Your sensitive personal data, such as race, religion, disability, political opinions, criminal history, biometric data (facial image data), health information, etc.

7. Cookies

       Nawabutr Clinic collects and uses cookies and other similar technologies on websites under the supervision of Nawabutr Clinic, such as www.nawabutrivf.com or on your device depending on the service you use. This is for the purpose of providing security services of Nawabutr Clinic and to provide you, the user, with a convenient and good experience in using Nawabutr Clinic’s services. This information will be used to improve Nawabutr Clinic’s website to better meet your needs. You can set or delete cookies yourself from your web browser settings.

 

8. Personal information of minors, incompetent persons and quasi-incompetent persons

       In the event that Nawabutr Clinic learns that personal information that requires consent to be collected belongs to the owner of the personal information who is a minor, incompetent person or quasi-incompetent person, Nawabutr Clinic will not collect such personal information until it has received consent from the person exercising parental authority to act on behalf of the minor or the guardian or custodian, as the case may be, in accordance with the conditions stipulated by law.

In the event that Nawabutr Clinic does not know in advance that the owner of the personal information is a minor, incompetent person or quasi-incompetent person and later found that Nawabutr Clinic has collected the data of the owner of such personal data without receiving consent from the person exercising parental authority who has the power to act on behalf of the minor or the guardian or the custodian as the case may be. As such, Nawabutr Clinic will proceed to delete such personal data as soon as possible if Nawabutr Clinic has no other lawful reason other than consent to collect, use or disclose such data.

9. Purpose of collecting personal data

       Nawabutr Clinic collects your personal data for various purposes, which depend on the type of products or services or activities you use, as well as the nature of your relationship with Nawabutr Clinic or considerations in each context. The purposes specified below are only a general framework for Nawabutr Clinic’s use of personal data. However, only the purposes related to the products or services you use or have a relationship with will be applicable to your data.

       1) To provide and manage the services of Nawabutr Clinic, both services under the contract with you or according to the mission of Nawabutr Clinic.

       2) For the transaction of Nawabutr Clinic.

       3) Control, use, monitor, inspect and manage the services to facilitate and meet your needs.

       4) To store and update information about you, including documents referring to you.

       5) Create a record of personal data processing as required by law.

       6) Analyze data, including solving problems related to Nawabutr Clinic’s services.

       7) To perform actions necessary for internal management of the organization, including recruitment, selection of directors or people holding various positions, qualification assessment.

       8) Prevent, detect, avoid and investigate fraud, security breaches or prohibited or illegal actions that may cause damage to both the organization and the owner of personal data.

       9) Verify identity, verify identity and verify information when you apply for Nawabutr Clinic’s services or contact to use services or exercise rights under the law.

       10) Improve and develop the quality of products and services to be up-to-date.

       11) Evaluate and manage risks.

       12) Send notifications, confirm orders Contact and inform you.

       13) To prepare and deliver relevant and necessary documents or information.

       14) Verify identity, prevent spam or unauthorized or illegal activities.

       15) Check how the owner of personal data accesses and uses the services of Nawabutr Clinic, both in general and individually.

       16) Take action as necessary to comply with the duties that Nawabutr Clinic has to the regulatory authorities, tax authorities, law enforcement or legal obligations.

       17) Take action as necessary for the legitimate interests of Nawabutr Clinic or of other persons or other legal entities related to the operation of the organization.

       18) Prevent or stop dangers to life, body or health of individuals, including epidemic surveillance.

       19) Prepare documents for services using assisted reproductive technology or compile statistics that Nawabutr Clinic is assigned to operate.

       20) To comply with laws, announcements, orders in effect or to proceed with litigation, to proceed with data in accordance with court orders, including exercising rights regarding your data.

10. Types of persons to whom Nawabutr Clinic discloses your personal data

Under the purposes specified in Section 9 above, Nawabutr Clinic may disclose your personal data to the following persons. The types of recipients of data specified below are only a general framework for Nawabutr Clinic’s disclosure of personal data. Only recipients of data related to the products or services you use or have a relationship with will be applicable.

Type of person receiving information

Details

Government agencies or authorities that Nawabutr Clinic must disclose information for the purpose of carrying out legal procedures or other important purposes.

Law enforcement agencies or agencies with regulatory authority or other important objectives, such as the Committee for the Protection of Children Born from Assisted Reproductive Technology and the Department of Health Service Support, etc.

Various committees involved in the legal operations of Nawabutr Clinic.

Nawabutr Clinic may disclose your information to persons who hold positions on various committees, such as the Committee for the Protection of Children Born from Assisted Reproductive Technology and the Department of Health Service Support, etc.

Contractual parties that operate on welfare of employees of Nawabutr Clinic.

External parties that Nawabutr Clinic procures to carry out welfare activities include insurance companies, hospitals, payroll companies, banks, telephone service providers, etc.

Business partners.

Nawabutr Clinic may disclose your information to persons working with Nawabutr Clinic for the purpose of providing services to you, such as medical laboratories, etc.

Service Provider.

Nawabutr Clinic may assign other persons to provide services on behalf of or support the operations of the organization, such as data storage service providers (e.g. cloud), system developers, software, applications, websites, document delivery service providers, payment service providers, internet service providers, telephone service providers, digital ID service providers, social media service providers, risk management service providers, external consultants, transportation service providers, etc.

11. Sending or transferring personal data abroad

         In some cases, Nawabutr Clinic may need to send or transfer your personal data abroad to perform the purpose of providing services to you, such as sending personal data to a cloud system with a platform or server located abroad (e.g. China or India, etc.) to support information technology systems located outside Thailand. This depends on the services of Nawabutr Clinic that you use or are involved in on a case-by-case basis.

However, at the time of the preparation of this policy, the Personal Data Protection Committee has not yet announced a list of destination countries with adequate personal data protection standards, as follows: When Nawabutr Clinic needs to send or transfer your personal data to a destination country, Nawabutr Clinic will take action to ensure that the personal data sent or transferred has adequate personal data protection measures in accordance with international standards or take action in accordance with the conditions in order to be able to send or transfer such data in accordance with the law, namely:

        1) Complying with the law that requires Nawabutr Clinic to send or transfer personal data abroad

        2) Having informed you and receiving your consent in cases where the destination country has inadequate personal data protection standards This is according to the list of countries announced by the Personal Data Protection Committee.

        3) It is necessary to perform a contract to which you are a party with Nawabutr Clinic or to comply with your request prior to entering into such contract.

        4) It is an act in accordance with a contract of Nawabutr Clinic with another person or juristic person for your benefit.

        5) To prevent or suppress danger to your life, body or health or that of another person when you are unable to give consent at that time.

        6) It is necessary to carry out a mission for an important benefit.

12. Period for collecting your personal data

         Nawabutr Clinic will keep your personal data for only the period that the data is still necessary for the purpose of collecting the data, as detailed in the policy, announcement or by relevant law. However, when the period has elapsed and your personal data is no longer necessary for the said purpose, Nawabutr Clinic will delete, destroy your personal data or make your personal data unidentifiable, according to the format and standards for deleting personal data announced by the Committee or law or international standards. However, in the event of a dispute, exercise of rights or lawsuit related to your personal data, Nawabutr Clinic reserves the right to continue to keep that data until the dispute has a final order or judgment.

13. Services by third parties or sub-service providers

         Nawabutr Clinic may assign or hire third parties (personal data processors) to process personal data on behalf of or on behalf of Nawabutr Clinic. Such third parties may offer various services, such as hosting, outsourcing, or cloud computing service/provider, or other forms of outsourcing.

         In assigning a third party to process personal data as a personal data processor, Nawabutr Clinic will provide an agreement specifying the rights and duties of Nawabutr Clinic as a personal data controller and of the person assigned by Nawabutr Clinic as a personal data processor, including specifying details of the types of personal data that Nawabutr Clinic assigns to process, including the purpose, scope of personal data processing, and other relevant agreements. The personal data processor is responsible for processing personal data only within the scope specified in the agreement and as instructed by Nawabutr Clinic, and cannot process it for other purposes.

         In the event that the personal data processor assigns a sub-service provider (sub-processor) to process personal data on behalf of or on behalf of the personal data processor, Nawabutr Clinic will direct the personal data processor to provide a document of agreement between the personal data processor and the sub-processor. In a format and standard that is not lower than the agreement between Nawabutr Clinic and the personal data processor.

14. Personal Data Security

         Nawabutr Clinic has measures to protect personal data by limiting access rights to personal data to only specific staff or persons with authority or assigned who need to use such data for the purposes notified to the owner of the personal data. Such persons must strictly adhere to and comply with Nawabutr Clinic’s personal data protection measures and have a duty to maintain the confidentiality of personal data that they learn from performing their duties. Nawabutr Clinic has measures to maintain data security, both organizationally and technically, that meet international standards and are in accordance with the announcements of the Personal Data Protection Committee.

In addition, when Nawabutr Clinic sends, transfers or discloses personal data to a third party, whether for providing services according to the mission, contract or other forms of agreement, Nawabutr Clinic will set appropriate measures to maintain personal data security and confidentiality in accordance with the law to confirm that personal data that Nawabutr Clinic collects will always be secure.

15. Links to external websites or services

        The services of Nawabutr Clinic may link to websites or services of third parties, which may have privacy policies that differ from this policy. Nawabutr Clinic recommends that you study the privacy policies of such websites or services to learn more before using them. Nawabutr Clinic is not involved in and has no control over the privacy measures of such websites or services and cannot be held responsible for the content, policies, damages, or actions caused by third party websites or services.

16. Data Protection Officer

         Nawabutr Clinic has appointed a Data Protection Officer to review, supervise, and provide advice on the collection, use, or disclosure of personal data, including coordinating and cooperating with the Personal Data Protection Committee Office to comply with the Personal Data Protection Act B.E. 2562.

17. Your rights under the Personal Data Protection Act B.E. 2562

         The Personal Data Protection Act B.E. 2562 stipulates several rights of data owners. These rights will come into effect when the law in this section comes into force. Details of the rights include:

         1) The right to request access to personal data. You have the right to request access Receive a copy and request disclosure of the source of personal data that Nawabutr Clinic has collected without your consent, except in cases where Nawabutr Clinic has the right to refuse your request for legal reasons or court orders, or in cases where the exercise of your rights will have an impact that may cause damage to the rights and freedoms of others.

         2) The right to request correction of personal data to be accurate, complete and up-to-date. If you find that your personal data is incorrect, incomplete or out-of-date, you have the right to request correction to make it accurate, up-to-date, complete and not misleading.

         3) The right to delete or destroy personal data. You have the right to request Nawabutr Clinic to delete or destroy your personal data or make your personal data unidentifiable to the owner of the data. However, the exercise of this right to delete or destroy personal data must be subject to the conditions prescribed by law.

         4) Right to request suspension of use of personal data You have the right to request suspension of use of your personal data in the following cases:

              a) During the period when Nawabutr Clinic is conducting an inspection at the request of the data owner to correct personal data to be accurate, complete and up-to-date

              b) Personal data of the data owner is collected, used or disclosed unlawfully

              c) When the personal data of the data owner is no longer necessary to be kept for the purposes that Nawabutr Clinic has informed in the collection, but the data owner wishes Nawabutr Clinic to continue to retain such data for the exercise of rights under the law

             d) During the period when Nawabutr Clinic is proving the lawful grounds for collecting the personal data of the data owner or examining the necessity of collecting, using or disclosing personal data for public benefit due to the data owner exercising the right to object to the collection, use or disclosure of personal data

          5) Right to object to the processing of personal data You have the right to object to the collection, use or disclosure of personal data about you, except in cases where Nawabutr Clinic has a lawful ground to refuse the request (e.g. Nawabutr Clinic can show that the collection, use or disclosure of your personal data has a more lawful ground or for the establishment of legal claims, compliance or exercise of legal claims)

            6) Right to withdraw consent In the event that you have given consent to Nawabutr Clinic to collect, use or disclose your personal data (whether such consent was given before or after the Personal Data Protection Act B.E. 2562 came into force), you have the right to withdraw your consent at any time during the period that your personal data is kept by Nawabutr Clinic, unless there is a legal restriction that requires Nawabutr Clinic to continue to retain the data or there is still a contract between you and Nawabutr Clinic that benefits you.

           7) Right to request, send or transfer personal data You have the right to request your personal data from Nawabutr Clinic in a format that is generally readable or usable by tools or devices that work automatically and can use or disclose personal data by automatic means, including requesting Nawabutr Clinic to send or transfer data in such format to another data controller. However, the exercise of this right shall be subject to the conditions prescribed by law.

18. Penalties for Non-Compliance with the Personal Data Protection Policy

        Failure to comply with the policy may result in an offence and disciplinary action under the rules of Nawabutr Clinic (for staff or operators of Nawabutr Clinic) or under the Personal Data Processing Agreement (for data processors), depending on the case and your relationship with Nawabutr Clinic, and may be subject to penalties as prescribed by the Personal Data Protection Act B.E. 2562, including secondary laws, rules, regulations, and related orders.

19. Complaints to regulatory authorities

        In the event that you find that Nawabutr Clinic has not complied with the Personal Data Protection Act, you have the right to complain to the Personal Data Protection Committee or a regulatory authority appointed by the Personal Data Protection Committee or under the law. Before making such a complaint, Nawabutr Clinic would like you to contact Nawabutr Clinic so that Nawabutr Clinic has the opportunity to be informed of the facts and clarify various issues, including addressing your concerns at the earliest opportunity.

20. Amendments to the Personal Data Protection Policy

        Nawabutr Clinic may consider amending, amending, or changing this policy as it deems appropriate and will notify you via the website www.nawabutrivf.com Each revised version is subject to the effective date. However, Nawabutr Clinic recommends that you check regularly for the new policy via the application or specific channels for activities that Nawabutr Clinic operates, especially before you disclose personal information to Nawabutr Clinic.

          Accessing the products or services of Nawabutr Clinic after the enforcement of the new policy is considered as acknowledgment of the terms of the new policy. Please stop using the service if you do not agree with the details in this policy and please contact Nawabutr Clinic for further clarification.

21. Contact for inquiries or exercise of rights

        If you have any questions, suggestions or concerns about the collection, use and disclosure of personal information by Nawabutr Clinic or this policy, or if you wish to exercise your rights under the personal data protection law, you can contact us at

1) Data Controller

– Name: Nawabutr Co., Ltd.

2) Data Protection Officer (DPO)

– Contact Address: 1 Q House Lumpini Building, 2nd Floor, Unit 219B-220, Sathorn Tai Road, Thung Maha Mek Subdistrict,

Sathorn District, Bangkok 10120

– Tel: 02-6777370-3

– Email: nawabutr4ivf@hotmail.com