MARKETING POLICY ON USE OF PERSONAL DATA FOR MARKETING PURPOSES
1. Consent for Marketing Purposes
1.1 If King Power Group[1] (the “Company”) wishes to collect, use and/or disclose the Personal Data for marketing purposes such as newsletters, public relations, communication, promotions of product(s) or service(s) through related contact channel e.g. website email telephone facsimile post SMS MMS Line or any social media to any person, the Company will inform such person of the collection, use and/or disclosure of the Personal Data for said marketing purposes and obtain a consent from such person as required by Personal Data Protection Act 2019 (the “Personal Data Protection Laws”) prior to or at such collection, use and/or disclosure of the Personal Data.
1.2 Prior to any marketing activities with any person the Company will ensure that the required consent is obtained. The Company will collect, use and/or disclose the Personal Data for marketing purposes only with such person’s consent.
1.3 In case of direct marketing a person has the right under the Personal Data Protection Laws to at any time dissent such collection, use and/or disclosure of his/her Personal Data. If dissented, the Company will not collect, use and/or disclose such Personal Data and will immediately separate such Personal Data in respect of the direct marketing from other purposes.
1.4 In case the Company collects the Personal Data prior to the effective date of the Personal Data Protection Laws, the Company has the right to continually collect and use said Personal Data for its original purposes. However the Company will prepare and inform the Data Subject of the procedure to revoke such consent so that the Data Subject not wishing the Data Controller to continually collect and use such Personal Data could easily revoke his/her consent.
[1] King Power Group means any and all company/companies as follows:
2. Marketing Message
If the Company wishes to send marketing messages or conduct telephone marketing to telephone number or through any communication means from 1st June 2021 onwards, the Company will ensure that it has obtained consent from such person to collect, use and/or disclose his/her Personal Data for marketing purposes.
3. Advertising and Invitation through Email, Post or Other Communication Means
From 1st June 2021 onwards the Company will not send to any person advertising or invitation to event participation through email, post or other communication means except with his/her prior consent to use the Personal Data for said purposes and such person previously received advertising and invitation or such activities comply with the Personal Data Protection Laws. It is recognised that distribution of advertising or invitation in essence is the use by the Company of the Personal Data for marketing purposes.
4. Responses to Information Request (Other than In-Person Communication)
4.1 If a person contacts the Company (via telephone, email, SMS/MMS, facsimile or post) requesting for available information on sales promotions or advertising, the Company may provide such person with the requested information. The Company should provide only the requested information and should not provide information not requested by such person or respond to such person through unrequested communication means.
4.2 If the Data Subject contacts the Company via telephone, the Company will avail internal records on date and time of such telephone contact, details to identify such person, requested matters and information provided by the Company. The Company should repeat or refer to the request of said person at the time the Company provides information to him/her. A response to provide information through communication means other than the one originally used by the Data Subject to contact the Company could be made only with such person’s request or permission. In case the Data Subject requests the Company to send the requested information via email or post, the Company’s email or post should contain the following contents or the like statements:
“We refer to our telephone conference on [INSERT DATE] during which you requested the Company to send you [INSERT DETAILS ON SUCH PERSON’S REQUEST SUCH AS BROCHURES]. We enclose herewith [INSERT DETAILS OF ENCLOSURE] as per your request.”
5. Marketing Messages Contained in Documents or Other Statements
In certain events marketing messages or sales promotion messages are contained in other documents such as at bottom of invoices issued by the Company to customers which may contain latest sale promotions, such display of the marketing messages on general documents distributed to the mass must be deleted. The marketing messages should be made in specific documents from general documents to ensure that said messages are conveyed to the person granting his/her consent to collect, use and/or disclose such Personal Data for marketing purposes only.
6. Email or Post Marketing
The Company will use email or person’s address for marketing purposes only with consent of such person to use his/her Personal Data for such marketing purposes at the time of such Personal Data collection and such consent remains unrevoked except that such activities do not require consent.
This 1st edition Policy is effective on 20thJune 2022.
Announced on 1st August 2022.