1. Scope of Application

This MPT Personal Data Protection Basic Policy is part of MPT’s Privacy Policy and describes the general rules how Magnecomp Precision Technology Public Co., Ltd. (“MPT”) processes personal data

2. Personal Data Processing Principles

MPT processes personal data in accordance with the following principles:

2.1 Lawfulness, Fairness and Transparency

Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency).

2.2 Purpose Limitation

Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose.

2.3 Data Minimization

Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.

2.4 Accuracy

Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay.

2.5 Storage Limitation

Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed.

2.6 Integrity and Confidentiality

Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at MPT are continuously adjusted.

3. Business Partner Data

In course of its business operations, MPT processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use MPT’s website or third party websites on which MPT has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners.

3.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with MPT.

3.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, data collected via active entries on MPT’s website and other electronic or non-electronic communication and interaction between MPT and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by MPT, data of users that access, browse or otherwise use MPT’s website or third party websites on which MPT has posted advertisements and data received from third parties including MPT and other Business Partners in compliance with applicable laws.

3.3 Processing Purposes

Personal data are processed for MPT’s business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to MPT’s business operations.

Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. MPT may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. MPT conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on MPT’s website and in user accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to MPT’s business operations. Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to MPT’s business operations.

3.4 Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which MPT is subject to and where the processing of personal data is in the legitimate interest of MPT. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue MPT’s business operations.

4. Recruitment Data

In course of its business operations, MPT processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

4.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel.

4.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, e-mails, facsimiles, letters, meetings, entries on MPT’s website and other electronic or non-electronic communication and interaction between an individual and MPT in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use MPT’s website or third party websites on which MPT has posted advertisements and data received in compliance with applicable laws from third parties including MPT Subsidiaries/affiliates and other Business Partners in course of a recruitment process, e.g. recruiting agencies and HR service providers.

4.3 Processing Purposes

Personal data are processed for searching and recruiting new personnel for MPT’s business operations including any activities reasonably related thereto.

4.4 Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with MPT, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which MPT is subject and where the processing of personal data is in the legitimate interest of MPT. Legitimate interests are the processing of the job application to find and recruit skilled personnel for MPT and MPT subsidiaries/affiliates and any activities related thereto.

5. Website Data and Cookies

For information about the processing of personal data on MPT’s website and third party websites, please refer to Policy for the Handling of Personal Data on MPT Websites and to the MPT Cookie Policy

6. Retention Periods

Personal data will be removed from MPT’s systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which MPT is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where MPT has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. MPT has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

Magnecomp Precision Technology Public Co., Ltd.is part of the TDK Group of Companies with joint business operations (https://www.tdk.com/corp/en/worldwide/index.htm). MPT may transfer data including personal data to other TDK Group Companies, Business Partners, courts, law enforcement agencies, government authorities, other public bodies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

7.1 Transfer to TDK Group Companies

Purpose of data transfers to other TDK Group Companies (https://www.tdk.com/corp/en/worldwide/index.htm) is the support the business operations of MPT within the TDK Group of Companies and the joint utilization of data. This may include joint business operations and the outsourcing of internal functions and the utilization of external resources, e.g. procurement and manufacturing, marketing, data analysis, Business Partner relationship management, research and development, education, administration, IT functions, HR functions, compliance with corporate organization and corporate governance rules and other activities reasonably related to MPT’s business operations. Categories of personal data transferred are described in 3.1 and 4.1 above.

TDK Group Companies that act as service providers are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by MPT. The same applies to any sub-providers of MPT’s service providers.

7.2 Transfer to Business Partners

Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to MPT’s business operations.

Business Partners that act as service providers for MPT are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by MPT. The same applies to any sub-providers of Business Partners’ service providers.

7.3 Transfer to government authorities, courts, law enforcement agencies

8. Transfer of Personal Data to other Countries

To the extent personal data are transferred to and processed in other countries than where MPT is established, MPT transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection.

9. Information Obligations

In compliance with applicable laws, MPT informs individuals about its personal data processing activities as described in the MPT Privacy Policy and the MPT Cookie Policy. MPT provides amongst others on and offline references to the MPT Privacy Policy on MPT’s website, electronic or non-electronic communication with individuals and electronic or non-electronic business documents to promote its data privacy activities.

10. Consent and Withdrawal of Consent

Where required under applicable data protection and other laws, MPT processes any data only after consent. Providing consent and data is voluntary. Before obtaining consent, MPT will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with MPT in respect of MPT’s business operations.

A consent can be withdrawn at any time with future effect by e-mail to Dpo.MPT-HTO@magnecomp.com. or by sending a withdrawal notice to the contact stated under 12. below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

Where MPT processes personal data of individuals, each individual may exercise its rights under applicable laws.

Any rights can be exercised by sending an e-mail to Dpo.MPT-HTO@magnecomp.com or to the contact details stated under 12 below.

In addition, each individual may lodge a complaint with a competent data protection supervisory authority.

Under the applicability of the Personal Data Protection Act B.E. 2562 (A.D. 2019) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”) any individual may exercise towards MPT the following rights:

• Right of Access,
• Right of Rectification,
• Right to Erasure,
• Right to restriction of processing,
• Right to object to processing,
• Right to data portability,
• Right to withdraw consent,
• Right to complain,
• Where MPT processes personal data for direct marketing purposes, each individual has the right to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling to the extent related to marketing purposes.

12. MPT Personal Data Protection Organization

MPT controls and is accountable for processing personal data collected from www.magnecomp.tdk.com. Please forward all inquiries regarding the processing of personal data to:

Magnecomp Precision Technology Public Co., Ltd.
Attn: Human Resources
162 Moo 5, Phaholyothin Road,
Lamsai Sub-District, Wangnoi District,
Ayutthaya 13170, Thailand
Dpo.MPT-HTO@magnecomp.com

13. Change Management

MPT may change the MPT Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on MPT Websites and the MPT Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from MPT.

1. Scope of Application

This Policy for the Handling of Personal Data on MPT Websites is part of MPT’s Privacy Policy.

It describes how Magnecomp Precision Technology Public Co., Ltd. (“MPT”) processes data of users that access, browse or otherwise use MPT’s website or third party websites on which MPT has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on MPT’s website and that MPT collects or otherwise obtains via cookies.

For detailed information about the use of cookies please refer to the MPT Cookie Policy.

2. Purposes

2.1 Services

MPT processes data including personal data for providing the following services in connection with its business operations (“Services”):

2.1.1 User Accounts

After registration, MPT offers personalized User accounts that allow access to product information and services and other information reasonably related to MPT’s business operations.

2.1.2 Inquiries and Requests

MPT offers the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.

2.1.3 Newsletters

After registration, MPT offers online newsletters by e-mail or other electronic means. Newsletter comprise information about MPT’s products, services, events, seminars, exhibitions, campaigns and other information reasonably related to MPT’s business operations.

2.1.4 Information Download

After registration, MPT offers information about products and services and other information reasonably related to MPT’s business operations.

2.1.5 Promotional Campaigns

MPT invites Users to take part in online promotional and other campaigns to bring MPT’s products and services and other information reasonably related to MPT’s business operations to the attention of current and potential customers and the wider public. MPT asks individuals to provide their comments and opinions about MPT’s products and services. MPT may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.

2.1.6 Recruitment

MPT may offer information about job vacancies of any kind on its website and invite individuals to file applications via MPT’s website.

2.1.7 PC and Mobile Application Software

MPT offers software for specific services and functions alone or in together with MPT’s products, services and other activities reasonably related to MPT’s business operations. MPT provides certain support services like software and firmware support. Software applications may create crash reports that help MPT and third party software developers to resolve any issues with the software.

Where required under applicable data protection and other laws, MPT processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, MPT will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use MPT’s website but may not able to benefit from some or all of the Services.

Regarding the withdrawal of a consent and other rights of Users, please refer to the MPT Personal Data Protection Basic Policy.

2.2 Marketing

For its marketing activities MPT processes data that Users have actively sent, transmitted or otherwise provided on MPT’s website for Services (see 2.1 above) and that MPT has collected or otherwise obtained via cookies from its and third party websites where MPT has posted advertisements. For detailed information about the use of cookies please refer to the MPT Cookie Policy.

MPT analyses such data alone or in combination or together with other data including personal data MPT has lawfully received. Data analysis activities may comprise automated processing including profiling. MPT may in particular combine data from the above-described direct and indirect online sources and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. MPT conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on MPT’s website and in User accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to MPT’s business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to MPT’s business operations.

Where required under applicable data protection and other laws, MPT processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, MPT will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use MPT’s website but may not able to benefit from some or all of the Services.

Regarding the withdrawal of a consent and further rights of Users, in particular to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling, please refer to the MPT Personal Data Protection Basic Policy.