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1. Scope of This Policy

This Privacy Policy applies to personal data collected through the following channels:

• The Company's website, online forms, and online assessment systems.
• Communications via email, telephone, messaging applications, and the Company's social media channels.
• Registration for and participation in training courses, seminars, workshops, coaching sessions, and other Company activities.
• Consulting, assessment, and people development services provided to corporate clients.
• Applications for employment with the Company.

Our Role in Processing Personal Data In general, the Company acts as a data controller. However, where a corporate client engages the Company to assess or develop its employees, the corporate client may act as the data controller, while the Company may act as a data processor within the agreed scope of services. In such circumstances, personal data will also be processed in accordance with the agreement with the corporate client and the client's applicable privacy policies.

This Privacy Policy does not apply to third-party websites or services linked through the Company's channels. Such third parties maintain their own privacy policies.

2. Personal Data We May Collect

The categories of personal data we collect depend on the services you use and your interactions with the Company. These may include:

Sensitive Personal Data The Company does not intend to collect sensitive personal data as defined under Section 26 of the PDPA. Where the collection of such data is necessary, the Company will obtain your explicit consent unless otherwise permitted by law.

Sources of Personal Data We primarily collect personal data directly from you. We may also receive personal data from other sources, including your employer or the organization engaging our services, individuals providing feedback in multi-rater assessments, third-party platforms you use to communicate with the Company, and publicly available sources.

If you do not provide certain necessary information, the Company may be unable to deliver services, process your registration, or consider your employment application.

3. Purposes and Legal Bases for Processing

The Company collects and processes personal data only to the extent necessary for the purposes described below. The applicable legal basis will depend on the circumstances of each processing activity.

Legitimate Interests Where the Company relies on legitimate interests as the legal basis for processing personal data, we will assess and balance those interests against your rights and reasonable expectations.

Consent Where processing is based on your consent, you may withdraw that consent at any time using the contact details provided in Section 8. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

New Processing Purposes If the Company intends to process your personal data for a new purpose unrelated to the original purpose, we will notify you and obtain your consent where required by law.

4. Disclosure and International Transfer of Personal Data

The Company does not sell personal data. We may disclose personal data, where necessary, to the following parties:

• Corporate Clients Where you participate in an assessment or development program on behalf of an organization, the Company may provide assessment results or reports to that organization within the agreed scope of services.
• Third-Party Service Providers These may include providers of cloud hosting, email services, website systems, assessment platforms, online meeting services, payment processing, analytics, and digital advertising services. Such providers process personal data subject to applicable agreements or service terms.
• Professional Advisers These may include auditors, legal advisers, and other professional advisers.
• Government Authorities and Legally Authorized Parties We may disclose personal data where required by applicable law or a lawful order.

International Data Transfers Some of the Company's service providers, including international assessment platform providers, may store or process personal data outside Thailand. Where such transfers occur, the Company will comply with applicable legal requirements governing international transfers of personal data.

5. Data Retention and Security

The Company retains personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy. Retention periods are determined by considering:

• The duration of our business or service relationship with you or your organization.
• Applicable legal retention requirements, including accounting and tax laws.
• Applicable limitation periods for legal claims.
• Agreements with corporate clients where the Company processes personal data on their behalf.

Once the applicable retention period has expired, the Company will delete, destroy, or anonymize personal data using appropriate methods.

Data Security The Company implements appropriate administrative, technical, and physical security measures to protect personal data. However, no system can eliminate all security risks. In the event of a personal data breach, the Company will notify the Personal Data Protection Committee Office and affected data subjects as required by applicable law.

6. Cookies, Marketing Communications, and Technology

Cookies The Company's website uses essential cookies required for the website to function properly. We may also use cookies for analytics and advertising purposes. Where required by law, we will obtain your consent before using non-essential cookies. You may subsequently change your cookie preferences or manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of some parts of the website.

Marketing Communications Consent to receive marketing communications is separate from the provision of our core services. You may unsubscribe from marketing communications at any time by following the instructions included in our messages or contacting us through the channels provided in Section 8. Unsubscribing will not affect the services you currently receive from the Company.

Use of Technology and Artificial Intelligence The Company may use software and technology tools, including artificial intelligence (AI), to support document preparation, analysis, and report generation. Such use is subject to the same data protection principles described in this Privacy Policy. The Company designs its assessment results to serve as supporting information for evaluation and decision-making. Decisions affecting individuals remain the responsibility of the organizations or individuals using those results.

7. Your Rights as a Data Subject

Subject to the conditions and limitations prescribed by applicable law, you have the following rights:

• Right of Access: Request access to and copies of your personal data, including disclosure of how personal data was obtained where you did not provide consent.
• Right to Data Portability: Request to receive or transfer your personal data in a commonly used, machine-readable format.
• Right to Object: Object to the collection, use, or disclosure of your personal data.
• Right to Erasure: Request the deletion, destruction, or anonymization of your personal data.
• Right to Restrict Processing: Request the suspension of the use of your personal data.
• Right to Rectification: Request corrections to ensure your personal data is accurate, up to date, and complete.
• Right to Withdraw Consent: Withdraw consent previously provided to the Company.
• Right to Lodge a Complaint: Submit a complaint to the Personal Data Protection Committee.

How to Exercise Your Rights You may submit a request in person, by post to the address provided in Section 8, or by email. The Company may request information reasonably necessary to verify your identity. Where a request is submitted on behalf of another individual, appropriate evidence of authorization must be provided.

Handling of Requests The Company will review and respond to requests within the timeframes prescribed by applicable laws and notifications issued by the Personal Data Protection Committee. We may refuse a request where permitted by law, including circumstances where disclosure would adversely affect the rights of another person or conflict with applicable law or a court order. Where a request is refused, we will inform you of the reasons.

Fees In general, the Company does not charge fees for exercising data subject rights. However, certain requests may be subject to fees where permitted by law, such as requests for physical copies of documents. Any such fees will not exceed the limits prescribed by law, and you will be informed before we proceed.

Where the Company processes personal data on behalf of a corporate client, we may refer your request to that organization in its capacity as the data controller.

8. Updates to This Policy and Contact Information

The Company may update this Privacy Policy to reflect changes in applicable laws, regulatory guidance, or our services. The latest version will be published on our website together with the date of the most recent update. Where material changes are made, the Company will notify you through appropriate channels where practicable.

If you have any questions about this Privacy Policy or wish to exercise your rights regarding your personal data, please contact the person responsible for personal data protection at the Company.