Privacy Notice
L.P.N. Development Group
We, L.P.N. Development PCL. and L.P.N. Development group, which names are illustrated in the appendix section (“L.P.N. Development Group,” “we,”, “our group”, “us,” or “our”)?respect your privacy and care about our customer’s (“you”, “your”) data privacy related to individuals (personal data). Therefore, we provide this privacy notice to inform our customers of our policy in relation to the collection, use, disclosure, and duration of storage or retention of your personal data in accordance with the Personal Data Protection Act B.E. 2562 (“PDPA”) and other applicable laws and regulations (“data privacy policy”). This privacy notice applies to
(1) Our customers
1.1 Individual customers : L.P.N. Development Group and affiliates’ past and present customers,
authorized individuals that act on behalf of the customers, first tenants, second tenants,
sub-lessees, residents, and visitors, etc.
1.2 Corporate customers : Directors, legal representatives of our corporate customers,
authorized individuals that act on their behalf. Our corporate customer shall ensure that the
authorized individuals have acknowledged our privacy notice.
(2) Non customers
For individuals who have no product or service with us or our potential customers, we may need
to collect, use, or disclose your personal data. These individuals include investors, visitors of our
sales offices, construction sites, legal offices, office branches, company websites, and
applications and also individuals who are interested in our projects in different channels. etc.
(3) Other individuals who we used to receive personal data such as emergency contacts, residents,
spouses, ascendants, descendants, relatives, sons, daughters, employers, representatives,
beneficiaries, and referees.
Please note that the individuals in 1-3 (“you”) shall acknowledge and pay attention to how we
collect, use, and disclose or share your personal data. We will strictly use the data as necessary to
develop our products and services to meet your interest.
This policy notice is used for our products and services that we sell, lease, or other services given
through our sales offices, legal offices, websites, phone applications, sales representatives, sales
booths, call centers, social media and online channels, registration to obtain goods, services, or
benefits and also other channels we received such data. Thus, kindly make sure that you have carefully
read the privacy notice while using our services or accessing such platforms.
Under this privacy policy, “data privacy” means personal information, which is used as
identification directly or indirectly and “sensitive personal data” is defined as the data privacy section
with special legal categories that must be treated with extra security.
We reserve our rights to amend this private notice from time to time so as to ensure its compliance
with the best practice of equivalent laws and will notify you by announcing this through our website or
applications.
Please be informed that some of the links on our platform may lead to third party’s platforms, and if
you access these platforms, your personal data will then be processed under those third party’s
policies. Kindly make sure that you have read the privacy notices of their platforms while accessing
through their channels.
1. How we collect, use, and disclose your personal data
We will strictly collect, use, and disclose your personal data where necessary or only when there is
a legal basis in collecting, using or disclosing the data. Our collection, usage, and disclosure of your
personal data is rooted in the legitimacy or legal obligation, obligated contract between you and L.P.N.
Development Group, our legitimate interests, your consent and other lawful basis. Purposes of
collecting, using, or disclosing your personal are described below
1.1 Legal Obligation
As a consequence of our company being regulated by many applicable laws, it is necessary to
fulfill our legal and regulatory requirements hence it is crucial to collect, use, or disclose your
personal data to comply with the applicable laws and government regulations due to following
purposes.
1) Compliance with the PDPA and any amendment thereof;
2) Compliance with laws (e.g. Financial Institution Business Law, Anti-Money Laundering
Law, Civil and Commercial Code, The Criminal Code, Prevention and Suppression of
Narcotics Act, Immigration Act, Condominium Act, Land Allotment Act), which also
include identity verification, background checks and credit checks, Know Your Customer
(KYC) process, Customer Due Diligence (CDD) process, other checks and screenings
(including screening against publicly available database of regulatory authorities and/or
official sanctions lists), and ongoing monitoring that may be required under any applicable
law; and/or
3) Compliance with regulatory obligations and/or orders of authorized persons (e.g. orders
by any court of competent jurisdiction or of governmental, supervisory or regulatory
authorities or authorized officers).
1.2 The contract that you have entered into with us
We will collect, use, or disclose your personal data according to the requests and/or
agreements you have entered into with the us. This includes but is not limited to the following
purposes:
1) Processing your request prior to signing the contract with us; Approval and provision of
products and/or services; Delivering products and/or services to you; Providing advice
and management regarding products and/or services. This comprises any of our
operations which, if not complied, will affect our operations or services.
2) Verifying your identity in every transaction.
3) Processing your instructions (such as purchasing or canceling a purchase of a
condominium or accommodation, transferring of assets, changing of rooms, requesting
for loans, checking customer’s credit, changing of products or services, transferring of
rights, leasing, requesting for cleaning services or other maintenance, processing your
requests and/or transactions or requests related to the use of our services or products, or
responding to your questions or suggestions
4) Providing our services via online banking, mobile applications, and other online product
platforms;
5) Tracking, recording, or notifying your transactions, rights, and benefits
6) Providing reports (e.g. transaction reports upon your request or other company reports)
7) Notifying of transactions and new products and/or notifying of due payment and/or
outstanding fee of products and/or services
8) Requesting for your owing debt to our group or the companies we manage
9) Conducting activities in customer relationship management
10) Taking action in relation to the maintenance of your user account and/or operating
accounts with respect to your account and/or operating accounts; including but not
limited to Processing of requests or requests for services or products; Processing of your
transactions, issuing a list of your user accounts; and/or Operating accounts and the
closure of your user account.
11) Processing or entering into transactions and/or payments (such as processing payments
or transacting Implementation of a successful transaction billing or carrying out activities;
Managing your relationship with the bank and the processing of your account with us)
12) Taking any action to comply with our contract (such as processing or tracking claims
under your contract)
13) Enforcing legal or contractual rights of our group and/or
14) Providing IT support and HelpDesk, creating and maintaining your code and user
account and managing access to any system to which you have been granted access,
while canceling inactive accounts
1.3 Our Group’s Legitimate Interests
We will refer to the base of legitimate interests by taking our group of companies, others, and
respect to the fundamental rights of your personal data. These base of interests are including but
not limited to the following purposes:
1) Managing our business (such as supervision, risk management, audit, financial and
accounting management, and internal management)
2) Managing our customer relations, including taking care of our customers, evaluating our
customer’s satisfaction, and handling our customer’s complaints, etc.
3) Managing our security (such as recording CCTV footage, registering, exchanging cards,
and/or recording contacts before entering the company’s premises. This includes, but is
not limited to, head offices, sale offices branches, legal offices.
4) Developing and improving our products, services and systems to raise our standards.
Using you personal data on the grounds of your preference to create products and
services to be most beneficial to you as well as meeting your expectations. In cases that
you wish to cancel your subscription, please let us know through our selected channel.
5) Recording images and/or audio related to meetings, training sessions, seminars,
recreational or marketing promotion activities.
6) Collecting, using and disclosing personal data of directors, authorized persons or
representatives in our group’s corporate customers.
7) Operating our business continuity
8) Handling claims and disputes, filing a lawsuit and taking relevant legal procedures.
9) Contacting you before you enter into any contract with our group
10) Preventing security risks (e.g. monitoring network activity logs, identifying security
incidents, conducting data security audits, and protecting against malicious, deceptive,
fraudulent or unlawful acts).
11) Conducting research, planning, and analyzing statistics (such as data analysis,
assessments, inquiries and reports about bank products and/or services and your
behavior).
12) Organizing promotional sales projects, meetings, seminars, and company visits;
13) Facilitating accounting audits performed by auditors.
14) Obtaining services from legal advisors, financial advisor, and/or any other consultant
appointed by you or our group.
15) Disclosing and transferring your personal data to one or more third parties as a part of
the transaction in case of our group companies' sale, transfer, merger, reorganization or
similar.
16) Retaining and updating your name list, directory, and personal to be up to dated, while
storing your contracts and related documents that may be referred to.
17) Complying with reasonable business principles (such as managing business operations
for our group to identify and resolve problems in our IT systems to ensure the safety,
development, operation and maintenance of technology systems in our group.
1.4 Your consent
In some cases, we may require your consent for the collection, use, or disclosure of your personal
information in order to provide you with the best benefit and/or to enable our group to provide
services to meet your demand for the following purposes
1) To develop and improve our product, services, working performance, marketing plan,
and service evaluation within our group.
2) To contact you to communicate and provide information about our products, services,
benefits, promotional sales, offers that are specifically tailored to you and may be of
interest to you. Furthermore, to inform about any changes regarding any personal data
privacy policy in the future.
3) To process your personal data according to our aforementioned purposes upon your
consent before collecting such data to serve the data collection purposes.
In case there is no consent nor provision of your personal data, we may not be able to
deliver our service according to your needs or our promise, and may result in the applicable laws.
We will strictly collect necessary personal data without your consent in cases that we have
a good-faith belief that access, use, preservation, or disclosure of the data is reasonably
necessary to meet any applicable law, regulation, legal process, or to protect against harm to the
rights and safety of the public as required or permitted by law.
1.5 Other legal bases
In addition to the above legal bases, we may collect, use or disclose your personal information
under other legal bases as follows:
1) Creating historical documents or archives for the public interest; or relating to research or
statistics;
2) Protecting or preventing or suppressing harm to life, body or health of persons;
3) It is necessary to carry duties in the public interest or for the exercise of competent
officials;
If the personal data we collect from you is necessary for our compliance with our group of
company laws or for entering into a contract with you, we may not be able to provide the service
(or continue to provide) some or all of our products or services to you, if you refuse to provide
your personal information to us upon our request.
2. Personal data that our group collects, uses, or discloses
The types of personal data we collect, use, or disclose will be varied depending on the scope of
the products and/or services you may have used or are interested in. It includes both general and
sensitive personal data. The information includes but is not limited to the following information:
1) Personal Information: e.g. name title, full name, alias, gender, date of birth, age, education,
marriage status, nationality, ID number, and passport number
2) Contact Information: e.g. address, current address, Email address, telephone number, mobile
number, fax number, and social media account (Email, Line ID, Facebook account, etc.)
3) Details for Identification and Verification: e.g. ID card photo, ID number, passport information,
important book information, alien ID card, driving license.
4) Work Information: e.g. occupation, details about employer and place of work, position, salary,
or compensation
5) Financial Data and Information about your Relationship with our group: e.g. current and past
products and/or services, channels and method of interaction with our group, customer status,
ability to acquire and manage credit payment, history transaction record, transaction details
(such as type, amount and other information related to your transaction)
6) Market Research Data, Market Data, and Sales: e.g. customer survey, information, and
opinions in market research, details of your services and your needs.
7) Geographic, Device, and Software Data: e.g. sales office visit, GPS location, computer IP
address, technical specifications and any other identifiable information (such as website
cookies, web beacon, device identifier, operating system, browser, and GPS location)
8) Data Access Information and Services Request: e.g. company’s login information, our group’s
transaction via internet and our applications
9) Security Data: e.g. photo, personality traits, detecting suspicious or unusual activity,
photographs or moving images through closed-circuit television cameras, record video
10) Sensitive Personal Data: e.g. religion, blood type, biometric data (such as face recognition and
fingerprint), criminal record
11) Loan Application Documents or Credit Scoring Information
12) Data Copy: e.g. photo, electronic documents or photocopied documents
13) Other data: e.g. record of communication between you and our group, including the
information you provided to us in any form, including but not limited to telephone calls, emails,
text messages, and social media communications through any channel
3. The source of your personal data
Our group generally collects personal information directly from you but in some cases, we may
obtain your personal information from other sources. We will proceed in accordance with the Personal
Data Protection Act. The personal data that the Bank collects from other sources may include, but not
limited to, the following information:
1) Information that we receive from our group of companies and affiliates, trusted business
partners, and/or other of our legal partners.
2) Information that we receive from persons associated with you (such as family, friends, referrals,
residents, tenants, etc.)
3) Information that we receive from our corporate customers as a director, authorized person, or
contact person.
4) Information that we receive from the service providers, government officers and agencies, third
parties (such as representatives, employers, sponsors, and other persons who provide your
information to us)
In cases that you have provided our group with your personal data of another person in
connection with our transactions or under any other circumstances, you will also need to notify such
individuals of the collection, use, and disclosure of their personal data and their rights according to this
Privacy Notice. You will also be required to obtain consent from that person (if necessary) or rely on other legal bases in order to provide your personal data to our group.
4. Your legal rights
The Personal Data Protection Act aims to make you more in control of your own personal data.
You can exercise your rights under the Act. to protect your personal data, which includes the following
details: according to the channel, specified by our group
4.1 Right to access and obtain a copy of your personal data
You have the right to access and obtain a copy of your personal data held by our group,
unless we have the right to refuse your request by law or court order or in cases that your
request will have an effect that may cause damage to the right and freedom of others.
4.2 Right to request for your personal data correction
You have the right to ask our group to make corrections or update your personal information
that is inaccurate or incomplete.
4.3 Right to request erasure of your personal data
You have the right to ask our group to delete or destroy your data or make your information
anonymous unless we have a legitimate cause to reject your request.
4.4 Right to request for suspension of the use of your personal data
4.4.1 Your personal data is collected, used, or disclosed illegally.
4.4.2 Your personal data is no longer served as stated in the purpose we mentioned while
collecting the data.
4.5 Right to object the collection, use or disclosure of your personal data
You have the right to object to the collection, use or disclosure of your personal information in
the event that our group operates under our legitimate interests unless there are grounds for
lawful refusal of your request (for example, our group can prove that the collection, use, or
disclosure of your personal data is more legitimate or for the establishment of legal claims
compliance or exercise of legal claims or for the public benefit of our companies).
4.6 Right to request for the transmission or transfer of your personal data
You have the right to obtain your personal data in cases where we can publish the data to be in
a readable form or format, with a device or other device that works automatically, which is able
to use or disclose the personal data, automatically. Moreover, you also have the right to ask
our group to send or transfer your personal information to third parties or obtain personal data
that we have sent or transferred to a third party, unless we are unable to do so by technical
conditions or we have legitimate reasons to refuse your request.
4.7 Right to withdrawal of consent
You have the right to withdraw the consent you have given to our group anytime according to
the procedures and methods prescribed by us, unless there are circumstances that we are
unable to withdraw your consent. Your withdrawal of consent will not affect the collection, use,
or disclosure of your personal information that has been given upon your legitimate consent
prior to your withdrawal of consent.
You are able to review and change your consent to the use or disclosure of personal data
for marketing purposes through the channels as written in Clause 10.
4.8 Right to complaint
You have the right to complain to the Personal Data Protection Committee or the Office of the
Personal Data Protection Committee, if there is any violation to the Personal Data Protection
Act
5. Disclosure of your personal data
We may disclose your personal data to the following persons or organizations: Under the
regulations of the Personal Data Protection Act.
1) Our group of companies and/or other persons that we have a legal relationship with including
directors, executives, employers, employees, contractors, agents, consultants of our group.
2) Government agencies and/or regulatory agencies for instance, The Securities and Exchange
Commission (SEC), Revenue Department, The Stock Exchange of Thailand (SET).
3) Partner, agents, or other organizations (such as independent auditor, securities depository
archives, etc.) as the disclosure of your personal data will serve a specific purpose under the
legal base and appropriate safety measures.
4) Individuals involved in the case of sale of claims and/or assets, reorganization, or our group
mergers which we may have to transfer the rights to such businesses including people who we
need to share information for the sale of claims and/or assets corporate restructuring, business
transfer, financial agreement disposition of property or any other transactions related to the
business and/or assets used in the operation of our group
5) Debt collection agents, lawyers, courts, authorities or any person to whom our group is
required or authorized to disclose personal data according to the law, regulation, or order.
6) Third parties who provide services to our group (such as IT service providers, marketing
analytics and benchmarking services providers, agents or subcontractors acting on behalf of
us, publishing providers).
7) Secured Social Media Service Providers or a third-party advertising company, who are
obliged to show you messages and any other person relating to our products and/our
services. The third-party advertising companies may use your online activity history in
conducting advertisements that may be of interest to you
8) Any other individuals who provide you with benefits or services related to our products or
services
9) Corporate customers as directors, legal representatives of our corporate customers,
authorized individuals to act on our behalf and/or
10) Your attorney, subordinate, representative or legal representative
6. Period of retention of your personal data
1) We will store your personal data according to the age limit or a period of time specified by
relevant laws or to comply with the objective in collecting the data. In cases that the data has
exceeded the legal timeframe or when the data is not required to serve the purpose you
consent to, or in cases that we have no rights or legitimation to collect, use, or disclose such
data, we will delete, destroy, or make your identification anonymous so as to use the data in
other beneficial terms, for example statistic analysis or working performance development.
2) We have implemented security measures within our group of companies and enforce a strict
policy to keep your personal data safe, technically and practically. This includes data
encryption and measures to prevent access, delete, change, amend or disclose to the
information without any consent to comply with appropriate standards of L.P.N.
Development group’s Information Security Policy.
7. Use of cookies
L.P.N. Development group may collect and use cookies and similar technologies when you use
our products and/or services including the use of the website financial transactions via the Internet and
our group of company’s applications. The collection of cookies and similar technologies will allow our
group to recognize you, know your preferences, and improve the way we offer products and/or services
to you. We may use cookies for a variety of purposes (for example, to enable basic functionality, to help
us understand how you use our website or Email. It also helps us to provide you with a better online
experience or communication with you. Lastly, to ensure that the online advertising material shown to
you is more relevant and interesting to you).
8. Use of personal data for its original purpose
Our group has the right to collect and use your personal information that we have collected prior
to the date of the Act. The protection of personal information in relation to the collection, use, and
disclosure of personal information is applicable according to the original purpose. If you do not wish for
our group to collect and use such personal data further You can notify the bank to withdraw your
consent through our provided channels.
9. Changes to our data privacy policy notice
We may change or amend this Privacy Notice from time to time. In that case, we will notify the
announcement of the current privacy policy on our website www.lpn.co.th
10. Our contact channels
Please find the contact information below, in case you have any questions, inquiries, or concerns
about our data privacy policy or if you would like to exercise your data privacy rights.
- LPN Call Center : 02-689-6888
- Email our Data Protection Officer : dpo@lpn.co.th
L.P.N. Development Group’s AFFILIATES
2. LPC Social Enterprise Co., Ltd.
3. Lumpini Project Management Services Co., Ltd.
4. Pornsanti Co., Ltd.
5. Lumpini Wisdom and Solution Co., Ltd.
6. LSS Solutions Security Guard Co., Ltd.