Privacy Policy
ENGINE MEDIA SOLUTIONS ASIA CO., LTD. (hereinafter referred to as the “Company”) establishes this Privacy Policy in accordance with Thailand’s Personal Data Protection Act B.E. 2562 (2019) (hereinafter referred to as the “PDPA”) and other applicable laws and regulations regarding the handling of personal data in connection with the website (engine-asia.com), portal sites, microsites, content, advertising and marketing services, events, and other services operated by the Company under the name “ENGINE” (collectively referred to as the “Services”).
The Company acts as the Data Controller of personal data under this Privacy Policy.
1. Definition of Personal Data
For the purposes of this Privacy Policy, “Personal Data” refers to any information that directly or indirectly identifies an individual or can be linked to an identifiable individual.
This includes, but is not limited to, names, company names, departments, job titles, addresses, telephone numbers, email addresses, information contained on business cards, online identifiers, and any other information that identifies or enables the identification of an individual.
2. Information We Collect
In connection with the provision of the Services and our business activities, we may collect the following information:
- Basic information, such as names, company names, departments, and job titles
- Contact information, such as email addresses, telephone numbers, and addresses
- Information contained on business cards
- Registration information for the Services (email addresses of registered users from listed companies, their affiliated companies, and login records)
- Information entered when downloading materials, catalogs, or other documents
- Information provided when submitting inquiries, requesting materials, or applying for business meetings
- Information provided when applying for job vacancies (name, email address, telephone number, reason for applying, current employer, preferred work location, résumé and other attached files, and the position applied for)
- Information obtained through exhibitions, seminars, events, business meetings, sales activities, and other related activities
- Information collected through participation in surveys, campaigns, and other promotional activities
- IP addresses (stored in truncated form), cookies, device information, browser information, access logs, browsing history, and other related data
- Other information provided through the use of the Services or in connection with transactions and communications with the Company
3. Methods of Information Collection
We collect information through lawful and fair means, including input forms on the Services, user registration, inquiries, downloads of materials and catalogs, job applications, email, telephone, business meetings, business card exchanges, exhibitions, seminars, events, surveys, and other appropriate methods.
We may also obtain information from publicly available sources, business partners, affiliated partners, and other third parties to the extent permitted by applicable laws and regulations.
4. Purposes of Use
We use the information collected to the extent necessary for the following purposes:
- Provision, operation, and management of the Services
- Provision of information tailored to users’ attributes, interests, and usage patterns
- Responding to inquiries and requests for materials, and forwarding inquiries to the relevant listed companies
- Receiving job applications and facilitating recruitment screening and selection by the listed companies to which applicants apply
- Provision of materials, catalogs, articles, videos, and other content
- Provision of product and service information by listed companies, member companies, and other relevant companies in connection with downloads of materials, catalogs, and other documents
- Business meetings, sales activities, transactions, and related communications
- Providing information about services, campaigns, events, seminars, new services, and other related offerings
- Conducting surveys, research, and other related activities
- Analyzing usage patterns and improving the Services, content, and marketing activities
- Detecting, preventing, and responding to unauthorized use and security-related issues
- Fulfilling contractual and legal obligations
- Other activities related or incidental to the purposes listed above
However, information submitted through forms on the Services (inquiries, catalog requests, and job applications) will be used only for the purposes specified in the respective forms (responding to inquiries and forwarding them to the relevant listed companies, providing catalogs, and conducting recruitment screening and selection).
Such information will be used for providing product and service information, sending various announcements, or conducting sales activities only when the individual has separately given their consent.
5. Information Collected Through Business Card Exchanges and Similar Activities
We may collect personal information through business card exchanges and similar interactions during sales activities, business meetings, exhibitions, seminars, events, and other business activities.
The information collected will be used, taking into account the circumstances under which it was obtained and our relationship with the individual, for business meetings, business-related communications, providing information about our services, invitations to events and seminars, providing information about relevant products and services, and other reasonably related business activities.
Where the individual's consent is required by applicable laws and regulations, we will obtain the necessary consent before using such information.
6. Legal Basis for Processing Personal Data
We process personal data based on one or more of the following legal grounds in accordance with the PDPA and other applicable laws and regulations:
- Consent of the individual: Where the individual has given consent (for sending various announcements and conducting sales activities, using cookies for website analytics, and sharing information submitted through forms with listed companies).
- Contractual necessity: Where processing is necessary for entering into or performing a contract with the individual (including responding to inquiries and requests for materials, and providing services to registered users of listed companies).
- Legal obligations: Where processing is necessary to comply with applicable legal obligations.
- Legitimate interests: Where processing is necessary for the legitimate interests of the Company or a third party, provided that such interests do not unjustifiably override the fundamental rights and freedoms of the individual (including preventing unauthorized use, ensuring the secure operation of the Services, and conducting business-related communications using information obtained through business card exchanges and similar activities).
- Other lawful grounds: Where processing is otherwise permitted under the PDPA or other applicable laws and regulations.
If you do not provide the required information in the respective forms, we may be unable to respond to your inquiries, provide catalogs, or accept your job applications.
7. Sensitive Personal Data
The Services do not collect sensitive personal data as defined under the PDPA, including information relating to race, ethnicity, political opinions, religious or philosophical beliefs, sexual orientation, criminal records, health, disabilities, trade union membership, genetic data, biometric data, or other categories of sensitive personal data specified under the PDPA.
When applying for job vacancies, please do not include such information in your résumé or any other attached documents.
Even if such information is included, it will not be used for any purposes other than recruitment screening and selection.
8. Use of Cookies and Similar Technologies
The Services use cookies and similar technologies for website analytics (Google Analytics) to understand usage patterns and improve the Services.
Analytics cookies are used only when users select “Accept” on the cookie consent banner displayed upon their first visit to the Services. If users select “Close,” analytics cookies will not be used. Google Analytics is configured to anonymize IP addresses and disable advertising features.
These technologies may collect information such as device information, browser information, pages viewed, access dates and times, referral sources, and other usage-related data.
Users may withdraw their consent at any time. By deleting the cookies and site data associated with the Services from their browser, the cookie consent banner will appear again on their next visit, allowing them to make a new selection.
Users may also disable cookies through their browser settings. However, doing so may prevent certain features of the Services from functioning properly.
9. Disclosure of Personal Data to Third Parties
We will not disclose personal data collected to third parties without the individual's consent, except where permitted under the PDPA or other applicable laws and regulations.
However, we may disclose personal data to third parties in the following circumstances, to the extent permitted by applicable laws and regulations:
- Where the individual has given their consent.
- Where, in connection with downloads of materials or catalogs, inquiries, requests for business meetings, job applications, or similar activities, the necessary information is provided to the relevant listed companies, member companies, or companies providing the information, after obtaining the individual's consent on the submission page. (The submitted information will be received by both the Company and the designated listed company. Résumés submitted for job applications will be accessed by the listed companies to which applicants apply through their member accounts.)
- Where disclosure is necessary to outsource all or part of our business operations to third-party service providers.
- Where disclosure is required by applicable laws or requested by courts, administrative authorities, or other authorized public institutions.
- Where disclosure is necessary to protect the life, physical safety, property, or other interests of individuals.
- Where disclosure is made in connection with a business transfer, merger, corporate split, or other form of business succession.
- Where information is provided in the form of statistical data or other information that does not identify any specific individual.
- Where disclosure is otherwise permitted under applicable laws and regulations.
10. Disclosure of Personal Data to Service Providers
We may outsource certain business operations to external service providers, including the operation of the Services, system management, cloud services, data analysis, email delivery, advertising distribution, content production, and other related activities. In such cases, we may allow these service providers to process personal data to the extent necessary for the performance of their contracted duties.
Our main service providers include:
- Google LLC (Google Cloud and Firebase: data storage, email delivery, and login authentication / Google Analytics: website analytics / Gemini API: assistance with article creation)
- Slack Technologies, LLC (internal notifications regarding inquiries received)
When outsourcing these operations, we will select appropriate service providers and implement necessary contractual arrangements, security measures, and oversight in accordance with the PDPA and other applicable laws and regulations.
11. International Transfer of Personal Data
Due to the global nature of our Services, personal data may be transferred to service providers, cloud service providers, business partners, affiliated partners, and other entities located outside the Kingdom of Thailand, or may be accessed by such entities from outside Thailand.
Data related to the Services is primarily stored on Google Cloud infrastructure located in Tokyo, Japan, and may be processed by the aforementioned service providers in the United States and other countries.
When transferring personal data outside Thailand, we will implement necessary and appropriate safeguards in accordance with the PDPA and other applicable laws and regulations, including assessing the level of data protection in the destination country, implementing contractual safeguards with service providers (such as standard contractual clauses), and taking other appropriate measures to protect personal data.
12. Data Retention Period
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, for the period required under contractual obligations, or for the period required by applicable laws and regulations.
The main retention periods for personal data collected through the Services are as follows:
- Inquiries and catalog requests: 24 months from the date of receipt (automatically deleted after this period).
- Job applications (including résumés and other attached files): 90 days from the date of receipt (automatically deleted after this period).
- Registered user information of listed companies: Until the user withdraws their membership (promptly deleted after membership termination).
- Service operation logs: 13 months (automatically deleted after this period).
When personal data is no longer required to be retained, we will take appropriate measures to delete, dispose of, or anonymize such data within a reasonable period, unless retention is required by applicable laws and regulations.
13. Data Security
To prevent unauthorized access, loss, destruction, alteration, leakage, misuse, and other risks, we implement reasonable and appropriate technical and organizational security measures according to the nature and risks associated with the personal data we process. These measures include encryption of communications, access authorization controls, activity logging, regular data backups, and other necessary safeguards.
We also provide appropriate training, supervision, and management for directors, officers, employees, outsourced service providers, and other parties involved in handling personal data.
14. Rights of Data Subjects
Under the PDPA and other applicable laws and regulations, individuals have the following rights regarding their personal data, subject to certain conditions:
- The right to access and obtain copies of their personal data
- The right to request correction of their personal data
- The right to request deletion or erasure of their personal data
- The right to request restriction of the use or processing of their personal data
- The right to object to the processing of their personal data
- The right to data portability
- The right to withdraw consent for processing based on consent (such withdrawal shall not affect the lawfulness of processing carried out before the withdrawal)
- The right to lodge a complaint with the Personal Data Protection Committee of Thailand
- Other rights recognized under the PDPA and other applicable laws and regulations
To exercise any of these rights, please contact us using the contact information provided in Section 17.
15. Personal Data of Minors and Other Individuals Requiring Legal Consent
When processing personal data of minors or other individuals who are legally unable to provide valid consent on their own, we will take appropriate measures in accordance with the PDPA and other applicable laws and regulations, including obtaining consent from parents, legal guardians, or other authorized legal representatives, where necessary.
16. Changes to This Privacy Policy
We may revise this Privacy Policy from time to time in response to amendments to applicable laws and regulations, changes to the Services, or other circumstances as necessary.
In the event of material changes, we will notify users or publicly announce such changes by posting them on the Services or through other appropriate means.
The revised Privacy Policy will take effect on the date it is posted on the Services or on another date separately specified.
17. Contact Information
For inquiries regarding this Privacy Policy, the handling of personal data, or the exercise of data subject rights, please contact us using the information below.
ENGINE MEDIA SOLUTIONS ASIA CO., LTD.
E-mail: info@engine-asia.com
Address: 101 True Digital Park, Pegasus Building, 5F, Unit 554 Sukhumvit Rd., Bang Chak, Phra Khanong, Bangkok 10260, Thailand
Effective Date: November 1, 2026