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        JP Dental Partnership Limited, the management and owner of the NP International Dental  Dental Clinic (collectively referred to as the “Clinic” or “We”), highly respects the privacy and the statutory rights over the personal data of the client who uses the medical services (collectively referred to as the “Client” or “You”). It is our highest priority and our mandate to protect and respect your privacy and your rights over your personal data with the most increased information security in all processes that we may undertake. We commit to implementing information security measures that meet the same professional level as the standardized medical centers and facilities and in the standard, as defined under the relevant laws of Thailand, in particular the Personal Data Protection Act B.E. 2562, and other relevant international standards.

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Privacy Notice

        Objective of Privacy Notice We, as the data controller, are fully aware of our obligations to inform the Client of this Privacy Notice that elaborates how we will process, collect, analyze and process the personal data of the Client and what are the statutory rights that the Client is entitled to as the data subject. Therefore, the Clinic has prepared and announced this Privacy Notice (“Notice”) and the Clinic commits to process the Client’s Personal data according to the relevant laws and in particular pursuant to this Notice.

        Scope of Application This Notice shall only be applicable to the personal data processing undertaken directly by the Clinic in the provision of services by us to you and shall not be applicable to the process of the personal data by any other third-parties, even those third-party services are connecting from the Clinic platform. It should be noted that the Clinic does not have any ability to control the data processing undertaken by those third-party; therefore, it is highly recommended that the Client should study the relevant privacy notices of those third parties that are separate from this Notice. 

        Amendment of this Notice. The Clinic reserve our right to make any amendment to this Notice from time to time in order to ensure the compliance with the relevant laws and the change in the service provisions that we are providing to you; provided that the Clinic will inform the Client of those changes by announcing the amended Notice via the communication channels that the Clinic may have.

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Acceptance of the Notice

        When the Client contacts the Clinic via any communication channels; gives information during the registration process; and shares any personal data with the Clinic, the Clinic shall deem that the Client accepts and acknowledges this Notice. It should be emphasized that the process of any personal data under this Notice is critical and essential for the performance of the duties that the Clinic have in providing the medical services and/or any other services to the Client as obliged and defined under the relevant laws and the contractual arrangement that we may have; therefore, in case the Client do not agree to this Notice (or any amendment hereof), the Client would not be entitled to use the services of the Clinic.

        Minor Client. Upon the receipt of the personal data of the data subject who is the minor either directly from the data subject with the authorization given by the legal guardian; or indirectly from the legal guardian, the Clinic would deem that the minor data subject accepts that the Clinic shall be able to process the personal data of those minor data subject under this Notice; provided that the Clinic shall not have any duty to verify the right and authority of the relevant legal guardian.

        Personal Data means any data that can be used to identify any single individual, either directly or indirectly, excluding the data of the deceased.

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Sources of Personal Data being Processed

        The Clinic may receive and collect the Client’s Personal Data from 5 main sources as follows:

1.Directly from the Client or the relevant persons in case the Client is unable to provide their own Personal Data to the Clinic. Personal Data will be collected from the contact that the Client make to the Hospital via various communication channels; during the preliminary assessment made and patient registration; during the treatment provided;

2.Indirectly from other medical center or service provider that the Client may contact and receive the treatment from. Those Personal Data will be collected and processed for the medical diagnosis and treatment as well for the vital interest of the Client;

3. Indirectly from other entity that have any relationship with to the Client that may share the Client’s Personal Data to the Clinic that is necessary for the Clinic to provide the relevant services to the relevant Client; provided that the Clinic shall deem that upon the receipt of those Personal Data from any person, the disclosing party shall represent and warrant to the Clinic that the disclosing party has the legitimate rights or obtain the consent from the relevant data subject to disclose those Personal Data to the Clinic while the Clinic shall have the right but not the obligation to verify such right of the disclosing party;

4. Indirectly from the third-party service provider who may provide related service to the Client, including without limitation the insurance company or any other third party service providers that the Client may contact and give consent to those providers to disclose the Client’s Personal Data to the Clinic (i.e., the online marketplace); and

5. Directly processed and collected by the Clinic while providing services that may include the medical diagnosis, analysis or treatment information that the Clinic may produce, prepare and process during the provisions of the relevant services by the Clinic to You, either online or offline, and the Personal Data being automatically collected by the Clinic system upon any contact made.

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Personal Data to be Processed

        For the contact-back; the patient registration; the coordination between the Clinic and You; the queue-booking; the provision of treatment and other ancillary services; and the delivery of products and services from the Clinic to you, the Clinic would need to process the Client’s Personal Data in each step as follows:

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During the First Contact Before the Service Use:

1. Full name and contact information (i.e., telephone number, email, social media account) will be collected;

2. General information relating to the Client’s symptom that will be collected and processed by the Clinic to give preliminary diagnosis prior to the provisions of any services or recommendation; and to respond to the Client’s preliminary request; and

3. In case the Client visits the Clinic’s website, IP address, browser and types of the devices used to connect to the website, time zone and location, operating system and other device information; as well as the cookies will be collected (please study the cookies policy separately from this Notice).

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During the Client Registration:

1. General information about the Client, including full name, identification card number, date of birth, telephone number and address will be collected;

2. Client’s identification documentation such as identification card (where the Clinic will collect the relevant information in the card automatically via card reader); passport or other identity document; and the image of the Client will be collected;

3. Client’s health information, including the symptom, temperature and vital signs value, general health information from the preliminary assessment will be collected, along with the Client registration process; and

Any Personal Data that shows the Client’s rights and entitlements that may relates to the services to be provided by the Clinic to the Client will be collected, including without limitation insurance coverage, social security benefits, for purposes to verify and check the Client’s rights and benefit.

During the Provision of Medical Services:

1. Facial image of the Client that visit the Clinic where the CCTV installed in our premises may collect; or that We may collect from any event that we hosted will be collected; provided that in case You do not want your photo taken in case of any event participation, please feel free to let us know;

2. Treatment and Diagnostic information, including body health checkup result; x-ray film or other microfilm; test results and finding; medicine and other medical treatment record; as well as photos and voices recorded during the treatment session, and the symptom update photos will also be collected for the purpose of follow-up and medical treatment provisions;

3. Payment information made for the any service used, including payment evidence, credit card information; or other evidence of the rights and entitlements that the Client may have (i.e., insurance claim) will be collected; and

4. We may collect other Personal Data that the Client may give and share with the Clinic in any other processes, including without limitation contact details, complaint or feedback submitted.

In case of any product purchase:

1. In case of online purchase, full name, contact and delivery information as well as the purchase transaction information will be collected by the Clinic; and

2. In case the Client request for the tax invoices, the identification card information or the Client record will be processed for the document preparation.

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Personal Data of other person that relates to the Client

        In case of emergency and with the purpose of protecting the vital interest or the Client, the Clinic may need to collect the contact information of the emergency contact person that the Client may give to the Clinic (the “Related Persons”), including without limitation full name, contact information and identity documentation of the Related Persons.

        Once the Client gives to Personal Data of the Related Persons to the Clinic, the Clinic shall deem that You have given the representation and warranty to us that you have the legitimate rights to disclose those Personal Data to us; therefore, the Clinic shall be entitled to process those Personal Data of the Related Persons pursuant to this Notice.

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Processing Purpose and Retention Period

        The Clinic would need to collect, use and process the Client and the Related Persons (as defined above) for the following purposes:

1. To perform our legal obligations to achieve the purposes with respect to medical diagnosis; the provision of healthcare and medical treatment; the management of public health; and the scientific and medical research or statistic; where the Clinic represent and commit to safeguard the fundamental rights and benefits of the Patient as the data subject under the relevant laws.

For this particular purpose, the Clinic would need to retain and collect the Client’s Personal Data for the period of time that are prescribed under the applicable laws.

2. To perform our contractual obligations that we may have with you, including without limitation:

§   To contact and coordinate with the Client; to respond and give relevant information as requested; to book the appointment and remind the Client of such appointment; to verify and check the Client’s rights and basic symptom prior to the commencement of the service provisions;

§   To provide medical service; to provide follow-up service, emergency or non-emergency; to provide continuous supports and advices to the Client after the hospitalized services, in particular for the provision of well-being and health advices to chronic patient that would require continuous care; and

§   To coordinate and contact for performance of other rights and obligations, including the payment collection and delivery of products from us to you.

For these particular purposes, the Clinic would need to retain the Client’s Personal Data for the period of time that the Clinic would have the contractual obligations to perform any services to the relevant Client.

3. To perform other legal obligation that the Clinic may have, for instance, the legal obligations in preparing the tax and accounting documentation (in particular in case the Client request for tax invoice); the legal obligations in submitting the medicine report to the relevant government authority (as required); and the legal obligations to maintain the Client information as defined under the standard for medical center; provided that for these particular obligations, the Clinic would need to retain those Personal Data for the period of time as obliged under the applicable laws.

4. To protect the vital interest of the Client in case there could be any potential immediate risk to the Client’s life, body or health and the Client may not be in the status that can give explicit consent to the Clinic to process, either the Personal Data or sensitive Personal Data, the Clinic would need to process the Client’s Personal Data for such immediate situation to protect the Client’s vital interest.

5. To protect and exercise the legitimate interest without causing excessive impact on the Client as the data subject, in particular for the following purposes:

§   To protect the legitimate right of the Clinic in case of any complaint or legal proceeding between the Clinic and the Client during the prescription period;

§   To manage the enterprise risk of the Clinic; and to maintain and ensure the service quality to be performed by the Clinic;

§   To analyze in the products and services planning of the Clinic that would match the interest of the Client; and to improve our relationship; and to manage and address any complaint or feedback given to the Client;

For these particular purposes, the Clinic would reserve the right to retain the Client’s Personal Data for the period of time that the Clinic may deem appropriate for the business benefit of the Clinic; provided that the Clinic commit not to cause excessive impact on the Client’s fundamental rights as the data subject.

6. With the Client’s consent, the Clinic would process the Client’s Personal Data for the purpose permitted by the Client until such consent is withdrawn, those purposes include without limitation:  

§   To use the success story or the Client’s Personal Data in the advertisement materials of the Clinic; provide that we commit not to infringe your rights over such Personal Data and respect your rights to make any comment on those materials prepared; and

§   To contact back to the Client to promote the information, promotions or other news that the Clinic may be interested in.

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Disclosure of Personal Data

Generally, the Clinic would not disclose or share the Personal Data of the Client to any person, except in case of necessity that the Clinic would need to disclose and share the Client’s

Personal Data to the following persons: 

1.  To the Person who provide medical benefits to the Client, including the insurance company in order for the Clinic to provide the relevant services to the Client to the fullest extent permissible under the benefit coverage of each relevant Client.

For the disclosure of the Personal Data to these persons, We commit to disclose only the relevant Personal Data that would be required for the Clinic to verify the Client’s rights and benefit under the agreed data processing agreement;

2. To the Third-Party Service Provider that the Clinic may engage in the provision of the relevant services to the Clinic, including without limitation the medical expertise providing relevant services on behalf of the Clinic; the medical examiner (i.e., lab, x-ray), other IT service provider or the consulting expertise.

        For the disclosure of the Personal Data to these third-party service providers, the Clinic will implement the appropriate information security of the Client’s Personal Data being shared and disclosed, including limit the Personal Data disclosed to the need-to-know basis and in case Personal Data being shared outside of Thailand, the information security that meet the requirement under the Personal Data Protection Act will be maintained;

3.  To government authorities that the Clinic may be obliged under the relevant laws and regulations or the government order to disclose and share the Client’s Personal Data to those government agencies; provided that the Clinic will only share the Personal Data on the need-to-know basis to serve such particular purpose; and

4. With the Client’s consent, the Clinic will disclose and share the Client’s Personal Data to the person that Client indicate, for instance, the disclosure of your health information the insurance company or affiliated company including other hospital or other clinic.

Information Security of the Personal Data

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The Clinic commit to implement the appropriate information security measures in strict compliance with the applicable laws to prevent the unauthorized access, use, change, revision or disclosure of the Personal Data and the Clinic shall review and revise the relevant information security measures on a regular basis to keep up with the improved technology and relevant security measures, both in organizational and technical aspects, in particular the Clinic will host the training and raise awareness among our staff to assure that they are all aware and respect your privacy and personal data.

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Data Subject’s rights over their Personal Data

        We fully respect your rights under the applicable laws as the data subject of the Personal Data being processed by the Clinic. The data subject shall be entitled to exercise the following rights under the permitted scope of the applicable laws, including: (1) the right to withdraw consent; (2) the right to request access or a copy of their Personal Data under our possession; (3) the right to request for data portability in case we restore the Personal data in a form that can be read or commonly used by automatic tools or devices and the right to request for the automatic port of those Personal Data to other data controllers, except such transferal cannot be operated due to technical reasons; (4) the right to object to any processing of their Personal Data; provided that in case of the right to object, the Clinic will only continue processing the Personal Data to the extent that there is sufficient legal justification that overrides the Client’s right as the data subject or processed as specifically required for the legal compliance or the legal defense purposes; (5) the right to request for the deletion or de-identification of their Personal Data if it is believed that those data are unlawfully processed; there is no longer necessary for the Clinic to proceed as defined under this Notice; or upon the withdrawal of consent or the exercise of the right to object; provided that it should be noted that such process may limit the Client’s access to some services that the Personal Data is required; (6) the right to request for the temporary suspension of Personal Data processing during the time that the Clinic is still considering the data subject’s request; and (7) the right to request for the rectification of their Personal Data to be accurate, current, complete and not misleading.

        You, as the data subject, can exercise the right by filling out the data subject right request form and handing it to the Data Protection Officer. It should be noted, however, that exercising of your right may be limited by applicable law and the Clinic necessities which the Clinic can refuse to respond to your request, for instance, in case the process of those Personal Data is required under the applicable law or court order; is required for the public interest; or such right exercised may infringe the rights or liberties of other persons. In case the Clinic needs to refuse such a request, the Clinic shall inform the Data Subject of the reason for the refusal.

        To emphasize our commitment to be fully in compliance with the Personal Data protection laws, the Clinic has appointed the Data Processing Committee as a part of the Clinic’s organization structure to monitor the compliance of the Clinic’s operation and the relevant laws, regulations and in particular this. In case you have any query relating to the Personal Data processing or would like to exercise any rights, please feel free to contact our Data Processing Committee.

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Contact Information:

Tel: 099 4466335    Line: @np_idc