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Privacy Notice

means the data subject whose Personal Data are processed by TRSC, including but not limited to investors, securities holders, website users, customers, investment professionals, staff, personnel, agent or broker, and other persons relating to the activities or the operations of TRSC.

“You”

1.  Definition

“TRSC”

means The Refractive Surgery Center Ltd. or TRSC International LASIK Center.

“Personal Data Protection Laws”

“Personal Data”

“Process” or “Processes” or “Processing”

means Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) and its relevant subordinate laws, including any amendments which may be made thereto in the future.

means any information relating to a natural person, which enables the identification of such natural person, whether directly or indirectly, but not including the information of the deceased person in particular, pursuant to the Personal Data Protection Laws.

means any operation performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure (by transfer, dissemination or otherwise making available), alignment, combination, restriction, erasure or destruction.

“Data Controller”

means a natural person or a juristic person having the power and duties to make decisions regarding the collection, use, or disclosure of the Personal Data.

"Data Processor"

means a natural person or a juristic person who operates in relation to the collection, use, or disclosure of the Personal Data pursuant to the orders given by or on behalf of a Data Controller, whereby such natural person or juristic person is not the Data Controller.

2. General Provisions

This Privacy Notice is provided to clarify the details and methods on how TRSC handles the information that we received from you, the purposes for the collection, use, disclosure, and processing, including the retention period of such Personal Data, and your rights as the data subject. As TRSC conducts business in Thailand, the processing of your Personal Data shall therefore fall under the compliance of and is required to comply with Thailand’s Personal Data Protection Laws accordingly.

3. About TRSC

With respect to the details in relation to TRSC and the Companies in TRSC (please click here). TRSC will process and keep protecting your Personal Data in accordance with the details as described in this Privacy Notice.

4. The methods to collect and receive your Personal Data

4.1    TRSC collects and receives your Personal Data via the following methods:​

a. Personal Data which you directly provide to TRSC: You may directly provide your Personal Data to TRSC. This case usually occurs when you contact TRSC to make enquiries, complete forms either by online or by document, apply for services or join activities, request for information, receive marketing communications, or provide comments or feedback to TRSC, etc.

​b. Personal Data which TRSC automatically collects from you: TRSC may automatically collect some technical information, in relation to your devices, activities and visiting patterns and browsing history, by using Cookies and other similar technologies. For more details, please see Cookies Policy

​c. Personal Data which TRSC receives from third parties: TRSC may, from time to time, receive your Personal Data from third parties, such as hospitals, medical centers, agents, banks, service providers, job recruiters, government organizations, contracting parties and professionals, personnel of TRSC and candidates.

4.2    In collecting your Personal Data, you will be informed of details set out in this Privacy Notice, including but not limited to, the lawful basis for the collection, use, disclosure and/or processing of Personal Data in accordance with the lawful purposes, or in the event that the Personal Data Protection Laws require your consent to be provided, TRSC will request for your explicit consent in order to process your Personal Data.

5. Collected Personal Data

5.1    Personal Data which TRSC collects and processes under this Privacy Notice is the Personal Data of the following categories of data subject:​

a. Patients and Customers i.e., natural persons who are patients, website visitors, service recipients, seminar participants, and other persons who contact TRSC to request information or services from TRSC, regardless of whether such Personal Data was directly or indirectly received.

​b. Contracting Parties, Professionals and other persons relating to the business of TRSC, i.e., natural persons who are contracting parties or contractually related with TRSC, including business partners, sellers, suppliers, service providers, contractors, advisers, and other similar persons.

​c. Personnel of TRSC, i.e., natural persons who are staff, employees or persons who work for TRSC, directors, managers, executives, professionals, and persons who directly receive monthly salaries, wages, benefits, or any other types of compensation from TRSC, including the family members of such personnel of TRSC.

​d. Candidates, i.e., natural persons who submit an application or details relating to their profile to TRSC, either in the form of written or verbal, with the purpose to apply for the job, internship/scholarship as staff or employees/interns/scholarship applicants of TRSC who are not yet chosen by TRSC, including the family members of such candidates and references.

5.2    Your Personal Data which is collected and processed under this Privacy Notice, regardless of whether such Personal Data was directly provided by you to TRSC or automatically collected from you by TRSC, or was provided to TRSC by third parties, such as​

​a. Personal Data, such as first name, last name, date/month/year of birth, age, gender, identification number and copy of passport or ID card, signature, nationality, marital status, and family members information.

​b. Sensitive Personal Data, such as religion, criminal record, health data, health examination result, disability, and biometric data.

​c. Contact details, such as address, telephone number, e-mail, social media contact details, and details of emergency contacts.

​d. Financial information, such as bank account number, and information regarding various types of tax.

​e. Information regarding the use of systems of TRSC, such as information regarding the registration or subscription for using TRSC’s systems (e.g., TRSC Member system, CRM system, TRSC Registration system, etc.), user account, account profile, username, password, and PIN (if any), information showing on account profile page and services applying page, information in your account profile that can be edited or amended by you, information received from other accounts that TRSC has a reasonable cause to believe that you are controlling such other accounts, service usage information, all interests and all comments that you express through systems of TRSC (if any), your activities participation information in systems of TRSC, survey information, information received from your communication with TRSC or TRSC’s working team.

​f. Technical information, such as the information of access to TRSC’s websites and systems, computer traffic data (Log), contact and communication information between you and other users, information from using records e.g., device indicator, computer IP address, device identification number, type of device, mobile phone network information, connecting information, geological information, browser category, system access record, information of referring application or website, use of system record, login log information, transaction log information, customer behavior information, system access statistics, access time, your searching information, the use of functions in systems, and information that TRSC collects through the use of Cookies or other similar technologies.

​g. Academic, Training, and Work Experience information, such as academic and training background, academic certificate or transcript, result or raking of points, level of education, language skills, professional licenses information, registration number, registration starting date, registration expiration date, registration renewal information, duty performance information, work starting date, information of training and test provided by TRSC or other relevant organizations, diploma, certificate, work experiences, monthly salaries or wages.

​h. Other information, such as photograph and/or voice recording by means of closed circuit television (CCTV), photograph, footage, video, voice recording of conversations and tendency information of goods or services purchasing

5.3    In the event that TRSC collected your Personal Data before 1 June 2022, TRSC will continue processing such Personal Data in accordance with the Personal Data Protection Laws.

6. Purposes and legal basis for collection, use and disclosure of Personal Data

6.1    TRSC processes your Personal Data for the following purposes (collectively referred to as “Specified Purposes”) and under the following legal basis:

  • For the benefit of treatment and consultation, or guidelines for treatment both in the present and in the future.

  • for preventing or suppressing danger to life, body or health of a person;

  • necessary for the performance of a contract which you have entered into as a party with the TRSC or for complying with your request prior to entering into such contract;

  • for compliance with the law by TRSC;

  • necessary for the legitimate interest of TRSC, or other persons or juristic persons other than TRSC;

  • necessary for the performance of a task carried out in the public interest by TRSC, or for exercising of official authority vested in TRSC;

  • for the achievement of the patient relationship service objectives. such as contacting to offer you the appropriate treatments and medical services.

  • for the achievement of purposes relating to research or statistics, for which suitable safeguard measures to protect your rights and freedom have been implemented;

  • for the achievement of communication objectives, answering questions or responding to complaints related to patient service and treatment.

  • consent which you have given to TRSC, where exceptions or legal basis specified above cannot be relied on, or according to the cases specified in the table below. In the case that TRSC has specifically requested consent from you for any Personal Data, TRSC will process such Personal Data pursuant to the purpose which you have been informed of and consented to, and TRSC will only process any Personal Data which constitutes sensitive Personal Data in the case that TRSC is able to do so under the laws or has obtained explicit consent from you.

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6.2    As the Personal Data which TRSC will process for the Specified Purposes as stated in Clause 6.1 above relates to the compliance with the laws or contracts or is necessary for entering into a contract with you, whereby, such Personal Data is necessary for the achievement of such Specified Purposes, if you do not provide such Personal Data to TRSC, there may be a legal impact or TRSC may not be able to perform its legal obligation under the contract entered into with you or may not be able to enter into a contract with you (as the case may be). In such case, TRSC may be required to decline to enter into a contract with you or terminate the relevant services to you, partly or entirely.

6.3    In the case that TRSC intends to use your Personal Data for a purpose not specified above, TRSC will provide an additional privacy notice to explain the use of Personal Data for such purpose. You should read such additional privacy notices along with this Privacy Notice.

7. Disclosure of Personal Data

7.1   TRSC may disclose your Personal Data under the Specified Purposes and in accordance with the laws and regulations to the following entities and persons:​

a. TRSC and the Companies in TRSC, including their staff, employees, directors, managers or personnel of TRSC as deemed relevant and necessary (on a need-to-know basis), for the processing of your Personal Data;

​b. Government organizations, regulating authorities according to the laws, such The Medical Council of Thailand, Department of Medical Services, Thailand Nursing and Midwifery Council, Food and Drug Administration, Health Systems Research Institute, Office of the Consumer Protection Board of Thailand, Department of Provincial Administration, Revenue Department, Department of Business Development, and Department of Intellectual Property;

​c. The organizations requesting for the disclosure of information by virtue of the laws, such as requesting information for the prosecution or legal prosecution, or relating to the legal proceedings, for example, The Medical Council of Thailand, Department of Medical Services, Office of the Consumer Protection Board of Thailand, Anti-Money Laundering Office, the National Anti-Corruption Commission, Royal Thai Police, Department of Special Investigation, Office of the Attorney General, and the courts;

d. Alliances, business partners, service providers, service recipients and Data Processors assigned by TRSC to be responsible of providing services or managing of Personal Data, such as improving or maintaining the security standard of the systems and the technology system, payment systems, audit, human resource management or other services which may be beneficial to you.​

7.2    The disclosure of your Personal Data to third parties shall be in accordance with the Specified Purposes or other purposes permitted by laws, provided that if the law requires your consent, TRSC will request for your explicit consent in advance.

7.3    In the event that TRSC discloses your Personal Data to third parties, TRSC will put in place appropriate safeguards to protect the Personal Data that has been disclosed and to comply with the standards and duties relating to the protection of Personal Data as prescribed by the Personal Data Protection Laws.

7.4    In the event that TRSC sends or transfers your Personal Data outside Thailand, TRSC will ensure that the recipient country, the international organization or such overseas recipient has a sufficient standard for the protection of Personal Data. In some cases, TRSC may request your consent for the transfer of your Personal Data outside Thailand, subject to the requirements under the Personal Data Protection Laws.

8. Retention Period

8.1   TRSC will retain your Personal Data for the period necessary to fulfil the Specified Purposes for which the Personal Data was processed, whereby the retention period may be changed depending on the Specified Purposes for which such Personal Data was collected and processed.

8.2  TRSC will also retain Personal Data for the period prescribed under the applicable laws, having regard to the business practices in relation to each category of Personal Data. After the aforementioned retention period, TRSC will delete such Personal Data from the storage or systems of TRSC without prior notice to you.

9. Personal Data of Minors

TRSC has no intention to serve minors as specific targeted groups. However, owing to the manner of organization, products and services of TRSC, TRSC may, occasionally, collect and process the Personal Data of the person who is under 20 years old. In such event, TRSC will comply with the Personal Data Protection Laws in relation to the processing of Personal Data of minors, including asking consent from the legal representative or guardian as prescribed by the Personal Data Protection Laws.

10. Rights of Data Subject

As the data subject, you have the following rights in relation to your Personal Data, subject to the rules, methods and conditions under the Personal Data Protection Laws. In this regard, if you wish to make a request to exercise your rights, you can contact TRSC by using the contact details set out below in Clause 13 (How to contact TRSC) of this Privacy Notice.

10.1  Right to Access
You have the right to access your Personal Data and may request TRSC to provide you with a copy of such Personal Data in accordance with the requirements under the Personal Data Protection Laws, including to disclose how the TRSC receive your Personal Data, which is collected, used and disclosed by the TRSC without requiring of your consent, to the extent permitted by the Personal Data Protection Laws.

10.2 Right to Data Portability
You have the right to obtain your Personal Data in the format which is readable or commonly used by ways of automatic tools or equipment, including to request to send or transfer your Personal Data to another Data Controller or to you, unless it is technically unfeasible to do so. Your rights to data portability shall be in accordance with the requirements under the Personal Data Protection Laws.

10.3 Right to Object 
You have the right to raise an objection to the processing of your Personal Data, and TRSC will conduct so in case that the TRSC;

a. ​processes your Personal Data based on our or third parties’ legitimate interest or public interest, except in the event that the TRSC can demonstrate compelling legitimate grounds, or the processing of your Personal Data is carried out for establishment, compliance with or exercise of the legal claims or defense of the legal claims;

b. processes your Personal Data for the purpose of direct marketing; or

c. processes your Personal Data for the purpose of scientific, historic or statistic research, unless it is necessary for conducting activities for the public interest of TRSC.

In the event that you object to the processing of Personal Data, please kindly inform us whether you wish to delete your Personal Data or to restrain TRSC from processing such Personal Data.

10.4 Right to Erasure
You may request TRSC to delete, destroy or anonymize your Personal Data in certain circumstances as follows:​

a. There is no further necessity to retain your Personal Data according to the Specified Purpose for processing your Personal Data;

b. You withdraw your consent which is the basis of collecting and processing the Personal Data, and TRSC has no legal ground for collecting or processing such Personal Data;

c. You object to the processing as mentioned in Clause 10.3; or

d. The collecting or processing of your Personal Data is unlawful.

The abovementioned cases shall not apply to the processing that is necessary for the purpose of freedom of expression, preparing of the historic or statistic documents, performing a task carried out in the public interest, complying with the law for achieving purposes with respect to preventive medicine or occupational medicine or public interest in public health, establishment, compliance with or exercise of the legal claims or defense of the legal claims or compliance with the law.

10.5 Right to Restriction
You have the right to request a restriction to the processing of your Personal Data in certain circumstances as follows:​

a. ​ TRSC is pending the verification of the accuracy of Personal Data as per your request;

b. In case of Personal Data which shall be deleted or erased according to Clause 10.4 that you request a restriction to the use instead;

c. TRSC has no further necessary to use your Personal Data, however, you have a necessity and therefore request TRSC to retain such Personal Data, for establishment, compliance, or exercise of the legal claims, or for defense of the legal claims; or

d. TRSC is pending the verification according to Clause 10.3 (a) or Clause 10.3 (c) in order to reject your objection request pursuant to Clause 10.

10.6 Right to Rectification
You have the right to request that your Personal Data be rectified if the Personal Data is inaccurate, not up-to-date or incomplete, or may cause a misunderstanding.

10.7 Right to Withdraw Consent
In the event that TRSC relies on your consent as the legal basis for processing your Personal Data, you have the right to withdraw such consent which has been provided to the TRSC at any time that such Personal Data is in the possession of the TRSC.

10.8 The right to file a complaint
If you have any concerns or questions about the processing of your personal data by TRSC Please contact TRSC By using the contact details in clause 13 (contact method) below in the event of a violation of the law on personal data protection. You have the right to file a complaint with the Office of the Personal Data Protection Commission.

TRSC will apply our best effort of the capability of the relevant systems to facilitate and carried out at your request without delay, unless it appears that to carry out at such request causes undue burden on or would involve excessive or disproportionate effort of TRSC or is in the risk of violating of the protection of others’ Personal Data or illegal or impossible to perform such request.

11. Security for the Retention of Personal Data

TRSC has in place and/or adopt the Personal Data storage systems, which has appropriate mechanism and technique and security standard according to the Personal Data Protection Laws and the relevant regulations, including the limitation of access of your Personal Data by staff, employees and representatives of TRSC for the purpose of preventing your Personal Data from the unauthorized usage, disclosure, erasure or access.

12. Link to websites, products and services of third parties

Provision of services of TRSC may link to websites, applications, products and services of third parties, which such third parties may collect certain information in relation to the use of such service. This Privacy Notice is solely applied to the processing of Personal Data under the purpose specified by TRSC. TRSC could not be responsible for the security or privacy or any of your information collected by websites, applications, products and services of such third parties, even you click the link appeared on the service of TRSC. In this regard, you should be careful and verify the privacy notice or privacy policy of websites, applications, products and services of such third parties.

13. How to contact TRSC

If you have any questions in relation to this Privacy Notice, or would like to exercise your rights as set out in this Privacy Notice, please kindly use the contact form published on the website of TRSC https://www.trsclasik.com/contactus

Also, you could contact TRSC through the Data Protection Officer of TRSC by using the following details;

 

  • Email : pdpa@trsclasik.com

  • Telephone Number : 02 632 4432

  • Fax Number : 02 632 4431

  • Mail to :
    TRSC International LASIK Center : Data Protection Officer
    6th Floor, U Chu Liang Bldg. 968 Rama IV Rd. Silom, Bangrak, Bangkok 10500 Thailand

14. Applicable Law

This Privacy Notice shall be governed by and construed in accordance with Thai laws, and Thai courts shall have jurisdiction over any dispute that may arise out of or relate to this Privacy Notice.

15. Changes to this Privacy Notice

TRSC may make changes to this Privacy Notice from time to time, in order to reflect any changes to our processing of your Personal Data, and to comply with changes to the Personal Data Protection Laws or any applicable laws. In this regard, TRSC will notify you of any significant changes to the Privacy Notice through appropriate means. Nevertheless, TRSC encourages you to review the Privacy Notice for any changes from time to time.

This Privacy Notice shall be effective from 1 June 2022

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