Shangri-La Hotel Public Company Limited ("Hotel", "we", "us", or "our") is using closed-circuit television (CCTV) devices for monitoring our designated space within and around our buildings and facilities to protect life, health, and property. We collect personal data of all customers, visitors, tenants, employees, directors, contractors, workers or any individuals entering the monitored space within our buildings and facilities (collectively referred to as "you" or "your") through the use of CCTV devices.

Most data protection laws around the world, including Thailand, consider the use of CCTV devices and similar surveillance technologies to be personal data collection. Therefore, the collection, use, disclosure, and overseas transfer of CCTV footage and images must be conducted in accordance with applicable data protection laws. We will ensure the use and operation of CCTV devices by our Hotel stands up to scrutiny and complies with applicable data protection laws and regulations.

This privacy policy provides information on our collection, use, disclosure, and overseas transfer of individually identifiable information ("Personal Data") about you. We may amend this policy at any time and will notify you of the amendments, where possible.

1. What Personal Data we collected 

The Hotel collects your moving or still images and belongings, e.g., vehicles, when entering the monitored space in our buildings and facilities through the CCTV devices ("CCTV Data").

2. Why we collect, use and/or disclose your Personal Data 

2.1 The Hotel may collect, use, disclose, transfer, and/or carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, or adding, related to your CCTV Data and other Personal Data concerning you, for the "CCTV Monitoring Purposes" as listed below:

• to protect your health and personal safety, including your belongings;
• to protect our buildings, facilities and assets from damage, disruption, vandalism, and other crime;
• to support law enforcement organizations in the deterrent, prevention, detection, and prosecution of crime;
• to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
• to assist in the investigation or proceedings concerning a whistleblowing complaint; and
• to assist in the establishment or defense of any civil litigation, including but not limited to employment proceedings.

2.2 We will install CCTV devices in plain sight. The areas we will not install CCTV devices are in guest rooms, staff rooms, changing rooms, toilets, shower rooms, or any other areas designated as staff rest areas.

2.3 Our CCTV devices are in operation 24 hours a day and 365 days a year.

2.4 We will place signage at the entrance and exit points, and the monitored areas to alert you that a CCTV installation is in use.

3. Legal bases 

The Hotel will not collect, use, disclose, process, transfer, and/or carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, or adding, related to your CCTV Data and other Personal Data concerning you, without consent except upon the following bases:

• Vital interest. It is necessary for our prevention or suppression of danger to a person's life, body, or health;
• Legitimate interest. It is in our legitimate interest to protect your health and personal safety, as well as your belongings, our buildings, facilities and assets, and to carry out any other acts to achieve the CCTV Monitoring Purposes. We will endeavor on the continuing basis to balance our legitimate interest and that of any relevant third parties, as the case may be, and your fundamental rights and freedoms related to the protection of the CCTV Data concerning you. We will also endeavor to identify any steps required to achieve the right balance as appropriate;
• Legal obligations. We owe a duty to comply with the legal obligations prescribed by the applicable laws, including but not limited to the laws regarding safety and environment in the workplace. We consider the use of CCTV as a necessary measure to enable us to meet those obligations.

4. To whom we may disclose or transfer your Personal Data 

4.1 The Hotel will keep CCTV Data concerning you confidential and will not disclose or transfer it except to our subsidiaries and affiliates, who may be located overseas, to achieve the CCTV Monitoring Purposes provided in this policy.

4.2 Third parties to which we may disclose CCTV Data and other Personal Data concerning you include:

• Shangri-La group companies and our affiliates. We may disclose or transfer CCTV Data and other Personal Data concerning you to Shangri-La group companies and our affiliated companies as part of our legitimate interest and our affiliates' interest to achieve the CCTV Monitoring Purposes.
• Governmental and/or regulatory organizations. We may disclose or transfer CCTV Data and other Personal Data concerning you to comply with legal obligations, or to support or assist law enforcement organizations with regard to the investigation and prosecution of civil or criminal proceedings.
• Third-party service providers. We may disclose or transfer CCTV Data and other Personal Data concerning you as our necessary steps to ensure our protection of your health and personal safety, and belongings.

5. International transfers of your Personal Data 

5.1 The Hotel may disclose or transfer your CCTV Data as part of necessary steps to ensure protection of your health, personal safety, and belongings, to our subsidiaries and affiliates that are outside of Thailand. Such disclosure or transfer may only be done by obtaining your consent, unless there are any other compelling legitimate grounds (e.g. to perform the contract terms between us and other persons for your benefit) as permitted by applicable laws.

5.2 If your CCTV Data is transferred to destination countries where the standard of protection available is not sufficient under the applicable laws on data protection in Thailand, we will take necessary steps to protect the Personal Data transferred to other persons internationally to reach the same level of protection as we provide with respect to your CCTV Data, and in compliance with the applicable laws on data protection that are in effect at that time.

6. Security measures  

6.1 The Hotel uses reasonable organizational, technical, and administrative security measures to protect CCTV Data and Personal Data concerning you from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure.

6.2 The Hotel will from time to time review and update our security measures as necessary or upon development of the concerning technology to ensure effective and appropriate security measures, and in line with minimum legal requirements as prescribed by the relevant governmental organizations.

7. How long do we keep your Personal Data 

The Hotel will retain your CCTV Data in our system for a minimum of 1 month and up to a maximum of 3 months, or for the period necessary to fulfil our duties to achieve the CCTV Monitoring Purposes prescribed in this policy. When we are no longer permitted by the applicable laws to store your CCTV Data, we will remove it from our systems and records. In the event that judicial or disciplinary action is initiated, your CCTV Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by the applicable laws.

8. Your rights as a data subject 

If you believe that you have been recorded by our CCTV devices, subject to applicable laws and exceptions thereof, you may have the following rights with respect to your Personal Data:

• Right of access. You have the right to access and request a copy of CCTV Data concerning you, or request us to disclose your CCTV data acquired without your consent. The request must be in writing and sent to our data protection officer, who can be contacted via dataprotectionofficer@shangri-la.com. Your request will be processed within 30 days from the date we receive your request. We may refuse your request following our legal rights or court orders, and where such access and request of a copy of the CCTV Data concerning you could affect the rights and freedoms of others. If it is decided that your request is to be refused, we will inform you by stating the reasons in writing and sending it to you within the period required by law;
• Rectification. You may have the right to have incomplete, inaccurate, misleading, or out-of-date Personal Data that we process about you rectified, where technically possible.
• Right of objection. You have the right to object to the collection, use, or disclosure of your CCTV Data if it is for the purpose of achieving our legitimate interest and/or that of other persons. Your request will be processed as soon as possible upon receiving your request. We may refuse your request if we can prove that there are more important legal grounds to collect, use, or disclose your CCTV Data, or such collection, use, or disclosure is for establishing claims, performing, defending or exercising legal claims, , or complying with the laws. If it is decided that your request is to be refused, we will inform you by stating the reasons in writing and sending it to you within the period required by law.
• Withdrawal of Consent. For the purposes you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time.
• Right of deletion. You have the right to request us to delete your CCTV Data or to render your CCTV Data to be unidentifiable to the extent applicable under the laws, except for cases where we may need to collect your CCTV Data as applicable under the law, such as establishing claims, performing, defending or exercising legal claims, or complying with the law.
• Data Portability. Where applicable, you may have the right to obtain your Personal Data which we hold, in a structured, electronic format, and transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent.
• Right of restriction. You have the right to request us to restrict your Personal Data which we no longer have the right to retain, if you need to use it for establishing claims, performing, defending or exercising legal claims, , or complying with the law.
• Right of complaint. You have the right to file a complaint against us to the competent government agencies if we breach or do not comply with the provisions under the applicable data protection laws which are in effect in Thailand, including our other policies or regulations.

9. Our Contact Details 

If you have concerns or questions regarding this policy or if you would like to exercise your rights in relation to your CCTV Data, please contact us at:

SHANGRI-LA HOTEL PUBLIC COMPANY LIMITED

Address: 89 Soi. Wat Suan Plu, New Road, Bang Rak, Bangkok 10500

Telephone: 66 (0) 2236 7777; or

Our data protection officer by email at dataprotectionofficer@shangri-la.com