The Royal Bangkok Sports Club and the RBSC Polo Club Member
PII to be Processed by RBSC in the Services Provision and the Communication
- General information relating directly to you that you have provided in the membership application form, the application for the use of any particular services or other documentations that you have submitted to RBSC in the form designated by RBSC (i.e. the notice of absence, the e-statement request, notice of membership transfer, locker request, parking request and permission as well as other registration of your dependent), in particular the membership card number and your full name, the nationality, date of birth, etc;
- Contact information, including residential address, contact address, telephone number, email that you have provided during the membership registration process and thereafter for any forms, including the complaint submission or lost-found request and form;
- The service transaction records and log information that include the details of the transactions that you have executed with RBSC, either online or offline, including the use of your log-in with the username and password, transaction history and other services that you have used and recorded in the membership system or the website and the payment information that you have transacted that may also include the details of your bank account and credit card information registered for the membership fees payment;
- Other technical information that can identify or link to your identity, including IP address, settings and browser connection that the user uses to connect to the Platform and may include various types of cookies used in order to track your behavior on the website;
- Other information that you may give for the purpose of marketing and sales promotion; the participation in the event, survey, competition, lucky draw; or any other promotional events and activities hosted by RBSC and other information relating to your preference and interest that RBSC may process to personalize the RBSC’s recommendation on services and/or products that would fit with your preference and interest, including also the photo and interview script that you have kindly permitted us to take;
- Upon receipt of your explicit consent, your sensitive PII (as defined under the applicable laws), including your facial recongnition information;
- Other PII that you may give to RBSC during the correspondence and communication for the service performance or any other PII that you may give the consent to RBSC to process.
RBSC may collect your PII in the following circumstances.
- When you contact RBSC (i.e. when you contact for any enquiry undertaken in person, on the website, on phone or via email);
- When you submit your PII for the membership registration, for the services and facilities used in various forms as provided and arranged by RBSC, either via the email submission or online channel, including on the Platform;
- When you participate in the survey, competition, lucky draw or other promotional events;
- When you give your feedback and opinion on RBSC’s services (i.e. survey gathering on the Platform); and/or
- When you submit any PII to RBSC for any other purposes.
In addition to the direct submission of the PII from you to RBSC (as defined above), RBSC may receive your PII from the third party sources that you may contact with and you have given consent to them to disclose your PII to RBSC; for instance, the submission of the referee or the dependent by other members. In such circumstance, RBSC shall deem that you have acknowledged that by receiving those information, RBSC believes and deems that you have given all the consent to the relevant person to disclose such PIIs to RBSC.
Objectives of the PII Process
The PII that you have provided to RBSC shall be collected and used for these particular purposes.
- For the purpose of membership and user verification for granting access to the membership privileges and benefits pursuant to the defined terms and conditions in the Membership Charter or the terms of services of the website; validation and confirmation of any transactions undertaken by you with RBSC (i.e. the facilities used) that may incur costs and expenses on you as defined under the terms and conditions of the Membership Charter; confirmation of the payment of any expenses or fees incurred for the use of any services or facilities; and for the purpose of contacting you with an aim to provide any supports or responses to any of your query relating to the member benefits and privileges;
- For the dissemination of any membership benefits, privileges or any other membership events that may be of any interst to you via the communication channel that you have identified as the preferred communication channel;
- For the creation and improvement of the business relationship between RBSC and you that may include the case where RBSC uses your PII for the employee training or supervisions to assure the service quality (in particular for the customer support staff provided through various channels); for analysis, investigation and complaint resolution;
- For the management of the communication and correspondence that you may contact RBSC (i.e. enquiry or complaint management or other feedback submission);
- For the analysis of your preference where RBSC may adjust the service provisions and channels which RBSC intends to use the best effort in fulfilling your interest and requests to the fullest extent and to create the good relationship between RBSC and you;
- For the purpose of preventing and inspecting any fraud or illegal use of RBSC’s services; assessing and managing the commercial risk or any other associated risks in other aspects of RBSC;
- For the purpose of assessing in the participation in the competition, promotional events or other activities that you may have agreed to enter into under the relevant defined terms;
- For the performance of any legal obligations that RBSC may have and for the compliance with the instructions given by the relevant regulatory authorities; for instance, for the tax payment purpose or any other obligations under the Computer Crime Act or the electronic transaction regulations;
- Other purposes that RBSC may consider related to the objectives already defined above.
RBSC is obliged to process and store your PII for the purpose defined above as long as you remain your membership status with RBSC and throughout the period of time as defined under the applicable laws; provided that RBSC reserves the right to retain your PII after the termination of the membership status for the period of 3 years thereafter for the purpose of facilitating you in case you would intend to resume the membership or for the legitimate interest protection in case of any dispute or complaint raised by you against us where RBSC may retrain your PII for the period of time as necessary to appropriate to fulfill the defined objective. Also, for the PII process that is being undertaken on the consent basis, RBSC will retain your PII for so long as until you have withdrawn your consent.
Disclosure of the PII
In general, your PII shall be kept in strict confidence by RBSC; provided that in certain circumstances, RBSC may have certain necessity to disclose the PII to these groups of people in order to fulfill RBSC’s contractual or legal obligations.
- To disclose to the outsourced service providers that have been engaged to provide direct services to RBSC in the performance of any obligation to you; for instance, the relevant professional counsel and other third party service providers engaged to provide performance assessment of the system and website; provided that always that RBSC shall disclose your PII only for the specified objectives and solely on the need-to-know basis;
- To disclose the operational information that may include your PII to the storage service providers on Cloud (that may be located in Thailand or abroad); provided that for the utilization of this particular services, RBSC assures to set the high confidential configuration and settings to assure the security in your PII at the level that reflects the level of confidentiality and risk exposure;
- To disclose your PII to third party in the legal proceedings to protect RBSC’s legitimate rights or to detect and prevent any fraud on RBSC’s system or the services that may also impact the third party’s rights; provided that such disclosure shall be done on the limited and specific purposes as explicitly defined;
- In case RBSC is obliged under the applicable laws, court judgment or administrative order to disclose any PII of any particular users, RBSC would need to do so only on the necessary basis;
- Other entity whom you may give consent to RBSC explicitly to disclose your PII to.
Cookies that RBSC Uses on Website Performance
Cookies are text files stored on your computer browser directory or program data subfolder in order to keep data log of your internet usage and behavior or interaction on the RBSC website. For the performance of the website, RBSC needs to use 2 types of Cookies for various purposes as defined below.
- Strictly Necessary Cookies are essential for you to browse the website and use its features, such as accessing secure areas of the website; and
- Other Cookies that may include Functionality Cookies used to record information about choices that you have made in the website; such as personal settings, languages, and fonts, so this would allow RBSC to tailor our website features that would match your preference settings; Performance Cookies used to assess the performance in any part of the website; and Advertising Cookies used to record your on-site behavior and history of the website visited and this would allow RBSC to provide you the services and products that suit your preferences and to assess the success of each function of the website.
For the use of Strictly Necessary Cookies, RBSC needs to use this Cookies for the performance of the website in full capacity and without this type of Cookies, RBSC shall not be able to provide the designated services to you. For other types of Cookies, RBSC will only use those Cookies upon the receipt of your consent.
Representation on the Appropriate Information Security of the PII
RBSC represents and guarantees that RBSC shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of the PII in any form or in any circumstance by either internal or external persons and RBSC commits to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws. Those measures may include the following measures.
- RBSC will use and store the PII in the anonymized form as much as possible by separating the PII from other information in order to reduce and mitigate the risk that any person receiving any piece of information may be able to use those information to identify the relevant individual;
- RBSC will encrypt most of the PII (if necessary) and shall limit the access control both physical and on the system and shall keep logs for all the PII access;
- RBSC shall adopt the inspection and monitoring scheme to monitor any threat, attack or any other unauthorized access to the PII. In this regards, RBSC shall configure and review the measures set on a regular basis as appropriate and RBSC shall establish a proper emergency response plan that includes the process of reporting the incident to the relevant Personal Data Protection Committee and the relevant data subject pursuant to the timeline set under the applicable laws; and
- In case of any PII exchange or disclosure to any third party outside RBSC’s environment, RBSC shall enter into the data processing agreement with the applicable receiving party in writing in order to set a clear scope of the rights and obligations of each party and shall establish a proper monitoring and management mechanism between the disclosing party and the receiving party; provided that such mechanism shall also include reporting obligations between the parties in case of incident or breach.
Data Subject Rights
RBSC respects your rights as the data subject over their PIIs as defined under the applicable laws that include the following rights.
- Right to access; to request for the copy of all the PIIs; and to rectify or update your PIIs;
- Right to request for the PII that RBSC has processed in the readable forms by the tools or automatic mechanics; and to request for the data portability to other data controllers;
- Right to object to the PII process being undertaken;
- Right to request for the erasure or de-identification of any PII that does not have any necessary basis to process i.e. after the consent withdrawal;
- Right to request for the PII process suspension in case that request for erasure is being exercised or when such PII is not necessary; and
- Right to withdraw consent that has been given for the PII process for specific purpose.
You as the member can contact RBSC in order to make the request to exercise any defined rights through the defined channel and RBSC shall notify you of the RBSC’s determination within 30 days after the receipt of the valid request.
Name: The Royal Bangkok Sports Club and the RBSC Polo Club
Contact Address: 1 Henri Dunant Street, Pathumwan Bangkok 10330
Telephone No. 02-0287272