Privacy Policy and Notice on the Processing of Personal Data Concerning Job Applicants and CandidatesofTHAI SHINMAYWA CO., LTD.
Thai ShinMaywa Co., Ltd. (the “Company”) gives importance to the protection of personal data
concerning its job applicants and candidates and the Company is well aware of its duties as data controller
under the Thailand’s Personal Data Protection Act B.E. 2562 (as may be amended or supplemented fromtime to time) including its implementing and/or supplemental rules, regulations, notifications andannouncements (the “Data Protection Law”). Therefore, the Company has prepared this Privacy Policy and
Notice on the Processing of Personal Data Concerning Job Applicants and Candidates (“Policy”) and hereby
notifies all of its job applicants and candidates of the Company’s collection, use, and disclosure of personal
data concerning its job applicants and candidates as well as their rights as data subjects as follows:1.

Definitions
Personal Data:

Any information relating to an individual which enables theidentification of such individual, whether directly or indirectly, but notincluding the information of the deceased person in particular.

Data subject(s):Any individual person who can be identified, directly or indirectly, by
Personal Data. (Under this Policy, data subjects are the Company's job
candidates and other persons specified in paragraph 2.2 of this Policy.)“Job candidates(s)”:Any job applicant i.e., any person applying for a job with the Company
through whichever channel and for whichever position, and/or any
person currently being considered by the Company for a job.

2.

Types of Personal Data concerning job candidates collected by the Company

2.1.

The Company collects the following Personal Data concerning job candidates and documents
containing such data:

2.2.



name-surname, photo, date of birth, age, sex, and nationality;phone number, email address, and address;

copy of ID card and/or copy of passport including ID number and/or passport number;military’s status;

job application form, expected salary, CV/resume, educational background, work experience,
training background, capabilities (e.g. language proficiency, typing skill, etc.), qualifications aswell as copy of educational and professional qualifications and certificates, outside activities,
and flexibility in working outside of Bangkok;

other personal data that the job candidates provided to the Company.

If necessary, the Company may collect Personal Data concerning other persons who are not the job
candidates as set out below (in which case, the relevant job candidate must, to the extent practicable,
obtain their consent to provide the Personal Data to the Company and/or notify them that the
Personal Data concerning them will be provided to the Company and the purposes thereof, as thecase may be):

name-surname, phone number, occupation/position, and relationship with the relevant job
candidate of the person notified/specified to the Company by the job candidate to be his/her
reference for further information concerning the job candidate.

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3.

Sources of Personal Data

3.1.

The Company may collect Personal Data concerning job candidates from the following sources:(1)

From the job candidates directly when they submit job applications or provide data to theCompany;(2)

From other persons who are not the job candidates as follows:

reference persons as specified/notified by the relevant job candidate to the Company;
and

recruitment companies that send Personal Data concerning job candidates to theCompany.

3.2.

The Company receives Personal Data concerning job candidates from the sources set out above in
written or verbal form, by the job candidates submitting or providing to the Company by themselves,
through phone calls, emails, posts, and obtained verbally from inquiries and job interviews.

4.

Collection, use and disclosure of Personal Data concerning job candidates and the purposes andlawful basis thereof

4.1.

The Company will duly collect, use and/or disclose Personal Data concerning job candidates on alimited basis pursuant to the purposes and the lawful basis set out below, and the procedures
pursuant to the Data Protection Law.

4.2.

The Company collects Personal Data concerning job candidates to use and/or disclose for thefollowing purposes:

4.3.

(1)

To verify the identity of the job candidates;(2)

To consider the qualifications of job candidates, support the job interview, for consideration
on job offers to the job candidates;

The Company relies on the following lawful basis under the Data Protection Law to collect, use and/or
disclose Personal Data concerning job candidates;(1)

The processing is necessary for proceeding in accordance with the job candidates’ request
before the Company considers entering into an employment contract or othercontract(s)/agreement(s) with the job candidates;(2)

The processing is necessary for the purposes of the legitimate interests pursued by theCompany or its parent or affiliate companies or other persons, except where such interests areoverridden by the interests or fundamental rights and freedoms of the data subjects.

4.4.

In addition, in the event that the Company agree to hire/employ any job candidate, the job candidate
is required to provide certain Personal Data concerning him/her (e.g. name, surname, ID number
and/or passport number, copy of ID card and/or passport, etc.) to enter into an employment contract
or other contract(s)/agreement(s) with the Company. Otherwise, the Company may be unable toenter into a contract/agreement with the job candidate.

4.5.

The Company does not disclose Personal Data concerning job candidates to any other persons.

5.

Retention of Personal Data concerning job candidates

5.1.

Retention of Personal Data concerning job candidates
The Company retains Personal Data concerning job candidates in both hard copy form andelectronic/soft copy form. Hard copies will be kept in locked cabinets at the Personnel and General
Affairs Section or the section(s) in charge of general affairs and personnel of the Company.
Electronic/soft copies will be stored in the Company’s internal computer system and internal server

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owned by the Company’s parent company, ShinMaywa Industries, Ltd., with its server located inJapan, both with password requirement for access.
Persons who have access to Personal Data
5.2.

Only all staffs of the relevant section and the Management of the Company would have accessto the Personal Data concerning job candidates.

Retention period for Personal Data concerning job candidates

5.2.1. The Company will retain Personal Data concerning job candidates and documents containing suchdata until the Company makes its decision whether to hire/employ the relevant job candidate, unlessa job candidate is employed or hired or selected to be personnel of the Company, in which case,please see paragraph 5.2.5 below.
5.2.2. Notwithstanding the Personal Data retention period set out in paragraph 5.2.1 above, if any law withwhich the Company must comply requires the Company to retain any Personal Data or any document
containing such data for a longer period than the relevant period set out in paragraph 5.2.1 above,
the Company will retain such Personal data or document for the period required by law.
5.2.3. If the Company considers that certain Personal Data and/or documents containing such data may benecessary or important for the Company’s establishment of a right of claim under the law, compliancewith, or exercise of a right of claim under, the law, or raising of a defense under the law, or may help
the Company in any potential dispute, claim and/or litigation in any form, the Company may retain
such data and/or document for a longer period than the relevant period set out in paragraph 5.2.1 orparagraph 5.2.2.
5.2.4. The Company will ensure to erase or destroy or anonymize Personal Data concerning job candidates
upon the end of the relevant retention period set out above, or erase or destroy or anonymize the
Personal Data that is irrelevant or unnecessary as per the purpose of collection of such Personal Dataor as requested by the relevant data subject who is entitled to such request, or erase or destroy oranonymize the Personal Data for which the relevant data subject has withdrawn his/her consent (onlyin case the collection of relevant Personal Data requires consent).
5.2.5. If a job candidate is employed or hired or selected to be personnel of the Company, the Company
may continue to retain and use the Personal Data concerning such job candidate and other Personal
Data concerning personnel for other purposes, in which case, the Company will further notify its
personnel pursuant the Data Protection Law.
6.

Security measures with respect to Personal Data concerning job candidates
The Company will implement appropriate measures to secure Personal Data to prevent unauthorized
or undue loss, access, use, change, amendment, or disclosure of Personal Data by using technologies
and other methods including the followings:(1)

The Company will classify the types of Personal Data and clearly define who has the right toaccess each type of such data.

(2)

The Company will store Personal Data securely.

(3)

The Company will set up a system to check and erase, destroy, or anonymize Personal Data as
specified in paragraph 5.2.4 above by appropriate means.

(4)

The Company will ensure that its personnel must enter their individual username and/or
password before accessing and using the Company's computer system and that such
usernames and passwords are kept strictly confidential.

(5)

The Company will take steps to prevent other persons to whom the Company disclose Personal
Data concerning job candidates from using or disclosing such data without authorization orwrongly.

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(6)

7.

The Company will notify any data breach incident with respect to Personal Data concerning job
candidates to the Office of the Personal Data Protection Committee without delay within the
period specified by the Data Protection Law. If such data breach has a high risk of affecting therights and freedoms of an individual, the Company will promptly notify the relevant data
subject of the incident with a plan to remedy the damage resulting therefrom without delay.

Data Subject’s Rights
A data subject is entitled to the rights in relation to the Personal Data concerning him/her asprescribed in the Personal Data Protection Law as follows:(1)

Right to Withdraw Consent In case the Company relies only on a data subject’s consent as its
lawful basis to collect, use and/or disclose Personal Data, the data subject may, at any time,
withdraw his/her consent. The Company will notify such data subject withdrawing his/her
consent of the effects that may occur as a result of his/her consent withdrawal at the time ofwithdrawal.

(2)

Right of Access A data subject has the right to access and request a copy of Personal Data
concerning him/her which are under the responsibility of the Company or request theCompany to disclose its acquisition of such Personal Data for which he/she did not giveconsent.

(3)

Right to Data Portability A data subject has the right to receive Personal Data concerning
him/her from the Company in case the Company has made such Personal Data in the format
that is commonly used and readable by automatic machine and can be used and disclosed byautomatic means. A data subject also has the right to request the Company to send or transfer
the Personal Data in such format to other data controller(s) if it can be done by automaticmeans and/or request to obtain the Personal Data in such format that the Company sends ortransfers to other data controller(s), unless it is technically unfeasible.

(4)

Right to Object A data subject has the right to, at any time, object to the collection, the use or
the disclosure of Personal Data concerning him/her under certain circumstances prescribedunder the Data Protection Law.

(5)

Right to Erasure A data subject has the right to request the Company to erase or destroy oranonymize Personal Data concerning him/her under certain circumstances prescribed under
the Data Protection Law.

(6)

Right to Restriction of Processing A data subject has the right to request the Company for
restriction of its use of Personal Data concerning him/her under certain circumstancesprescribed under the Data Protection Law.

(7)

Right to Rectification A data subject has the right to request the Company to rectify inaccurate
Personal Data concerning him/her and ensure that the Personal Data concerning him/her is
up-to-date, complete and not misleading.

(8)

Right to Lodge Complaint A data subject has the right to lodge a complaint with the competentauthority or committee under the Data Protection Law in the event that the Company including
its personnel or contractor(s)/service provider(s) violate or fail to comply with the Data
Protection Law.

The data subject can contact the Company in order to exercise any right under subparagraphs (1) –(7) above as per the details set out in paragraph 9 below.
8.

Modification of Policy
The Company may review and revise this Policy on a regular basis as to ensure its consistency withthe relevant guidelines and the Data Protection Law. The Company will notify the data subjects ofPrivacy Policy and Notice on the Processing of Personal Data Concerning Job Applicants and Job Candidates
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such changes to this Policy by publicizing the updated Policy on the Company’s website as soon as
possible.
9.

Information about the Company and contact details
If a data subject has any question or suggestion in relation to the Company’s protection of Personal
Data or wishes to exercise a right as data subject, please contact the Company’s Personnel andGeneral Affairs Section (or the section in charge of general affairs and personnel of the Company) as
per the following contact details:
Company’s Name:

Thai ShinMaywa Co., Ltd.

Address:

199, 199/1 Moo 12, Soi Petchakasem 120, Petchakasem Road, Om
Noi, Krathum Baen, Samutsakorn Province 74130, THAILAND

Contact Channels:

Tel.: 0-2420-0089 ext.26
Email: tsmc@shinmaywa.co.jp

Website:https://www.shinmaywa.co.jp/thai/english/index.html
This Policy is last updated in March 2023.

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