Shareholder Policy
Shareholders and Investors Privacy Policy
Jubilee Enterprise Public Company Limited (“the Company”) assures shareholders, investors and/or any person interested in the Company’s investment (“you”) that all of your personal data is important to the Company. The Company guarantees to protect and process personal data with the most appropriate security measures. The Company intends to inform you as a shareholder who invests in the Company’s shares and investors or any person who contacts to inquire about the Company about this Privacy Policy for Shareholders and Investors (“Privacy Policy”), which specifies the necessity to collect, compile, process, use, including disclosure or forwarding of your personal data that the Company is required to do in order to perform its duties as a Company towards you as a shareholder and investor under the law, namely the Public Limited Companies Act and the Civil and Commercial Code. If you do not agree to allow the Company to process your personal data in accordance with the terms and conditions specified in this Policy, the Company would like to inform you that the Company will not be able to perform its duties towards you.
Personal data processed
Basically, your personal data as an investor, shareholder and/or person interested in the Company's investment that the Company may need to process is divided into 2 main categories: (1) general personal data and
(2) Sensitive personal data
The Company intends to limit the processing of both types of personal data, especially sensitive personal data, to the extent necessary. “Personal Data” means information about each investor, shareholder and/or person interested in the Company’s investment that can identify you, whether it is the part of the information that the Company may receive directly from you providing information to the Company or from checking the Company’s shareholder register, which the Company is required to collect and compile by law. This may include cases where the Company may receive your information according to the shareholder register from the Securities Depository (Thailand) Co., Ltd., which provides securities registrar services to the Company. The Company is required to collect, compile and use the following personal data: General information about you as a shareholder, namely, your name, surname, nationality, occupation, current address, number of shares held, your bank account information, national identification number, email and contact number. In the case that you are a major shareholder as defined in the criteria of regulatory agencies, including but not limited to the Securities and Exchange Commission and the Stock Exchange of Thailand, the Company is required to collect and compile additional personal data about you, namely, your background (e.g. educational background, work experience, etc.) and photos of you or representatives of such juristic shareholders. General information about you as a shareholder, investor and person interested in the Company’s investment that you may provide to the Company during communications or conversations that you may have with the Company through investor relations channels. This may include but is not limited to your name, surname, nationality, occupation, address and contact information (including telephone number and/or email), meeting attendance information that the said shareholder participates in the shareholders’ meeting, which may include meeting registration information, which may include information of proxy holders on behalf of the shareholder, along with audio-visual recordings during the meeting, both online and offline, and other personal data that you may consent to and submit to the Company for processing for other specific purposes. In the case of shareholders who hold shares in the name of a juristic person, the Company is required to collect and use information of the Company’s directors, or in the case that the shareholder authorizes other persons to attend the meeting and exercise their rights under the law, the Company is required to process such persons’ information as processing for you as a shareholder. In such case, when you submit personal data of such other persons to the Company, the Company shall be deemed to have provided a guarantee that you have obtained consent or have the right to disclose such persons’ personal data to the Company.
Purpose of collecting personal data
The Company collects and uses your personal data for various purposes, including the following purposes:
To perform the Company's legal duties towards you in accordance with your shareholder rights.
Such as company management (e.g. establishment, capital increase, capital reduction, business restructuring, change in registered items), sending meeting invitations or other notices to inform shareholders of their rights under the law, such as the invitation to the general shareholders’ meeting of the company or sending the company’s business report to shareholders in accordance with the rights that shareholders have under relevant laws, including the distribution and distribution of dividends to shareholders who are related and entitled, the preparation of accounts and reports, the examination of legal documents, including the legal duties of a public limited company and a company listed on the Stock Exchange of Thailand. In order to exercise the rights and duties to such shareholders, the company must confirm the identity of you or your authorized representative or proxy in showing your rights as a shareholder who will exercise various rights, such as the right to attend meetings or the right to transfer shares, etc.
Managing your response to communications with the company
For example, to inform or publicize various information about the Company's management that may be directly related to your investment and shareholder status, to communicate and answer your inquiries, to manage complaints, to exercise shareholder rights, or to provide various opinions, etc.
For the legitimate interests of the Company or another person.
For example, the management of the company in analyzing the shareholder structure, for recording the organization and management of the meeting, such as registration for the meeting, recording the vote, recording the audio and/or video during the meeting for the purpose of publishing the meeting via the company's website and other contact channels, which is considered a case of action for legitimate interests to ensure the transparency and good governance of the company, including for the benefit of shareholders, etc., data analysis, conducting activities and facilitating shareholders in the case of organizing other special activities that the company may organize for you as a shareholder, risk management and internal control of the organization, supervision and audit, including internal audit, including the exercise of legal claims.
Especially in the case of major shareholders
As defined, for the purpose of preparing the Company's annual report documents as required by the Company and may be required to be submitted to relevant agencies or disclosed to the public in accordance with the terms and conditions stipulated by relevant laws, which may include disclosing your information via the Company's website, performing duties in accordance with laws, announcements, regulations or orders of agencies, especially regulatory agencies or officers with duties and powers under the law, including judgments of any other courts that the Company may be required to perform correctly and completely, including but not limited to the Securities and Exchange Commission, the Stock Exchange of Thailand, the Ministry of Commerce or other agencies.
Period of processing of your personal data
The Company is required to process and collect your personal data for the purposes stated above only as necessary.
(i) in response to any communication that you, as an investor or any other person, contact the Company, or
(ii) for as long as you remain a shareholder of the Company and the Company is still legally liable to you; or
(iii) for any period that the Company may be required under other laws to retain your personal data. In addition, for the purpose of verifying and protecting the rights of the Company and you under the status of the Company and shareholders, the Company reserves the right to retain the personal data of shareholders for an additional appropriate period of time in accordance with the appropriate statute of limitations after you cease to be a shareholder, in case there may be any claims you may have against the Company. In such case, the Company will retain your data for the period that may be expected according to the collection standards (e.g. the general statute of limitations of up to 10 years).
Disclosure of Personal Information
In principle, the personal data you provide to the Company will be kept confidential. However, in some cases, your personal data may need to be disclosed to the following groups of persons: external service providers who assist the Company in conducting its business and performing its legal duties towards shareholders, including protecting the Company’s legitimate rights, including but not limited to Thailand Securities Depository Co., Ltd. as the Company’s securities registrar, legal advisors, accounting advisors and other advisors, as well as internal and external audit departments, etc. The Company guarantees that the disclosure will be made only in accordance with the data processing objectives specified and only on the basis of necessity. In cases where the Company is required by law or is subject to a judgment or order of a government agency, the Company may need to disclose your personal data to such agencies in order to comply with its legal duties. The Company will only do so to the extent necessary for such duties. In some cases where the Company may need to disclose the Company’s annual report, which may include personal data of the Company’s major shareholders for the purpose of entering into a contract or liaising with the Company’s contracting parties, the Company may need to disclose your personal data, which is a major shareholder, to such contracting parties. The Company will act on the principle of the Company’s legitimate interests and will only act as necessary without unreasonably affecting the rights of the data owner; and other agencies to which you have expressly consented for us to disclose such data.
Assurance of implementation of appropriate data security measures
The Company has in place appropriate security measures to protect against unauthorized or unauthorized access, use, alteration, modification or disclosure of personal data. In addition, the Company has established internal practices to determine the rights of data subjects to access or use personal data in order to maintain the confidentiality and security of the data. The Company will periodically review such measures to ensure their appropriateness in line with industry standards and compliance with relevant laws.
Data Owner Rights
The Company acknowledges and respects your legal rights as a shareholder in relation to your personal data under the Company’s control in accordance with the rights specified in the law, as follows: The right to request access and request a copy of your personal data, including the right to request correction of personal data to be current and accurate; The right to request personal data in case the Company makes such personal data in a format that can be read or used by general people with automatic tools or devices, including the right to request that such data be sent or transferred to another data controller; The right to object to the processing of personal data; The right to request the deletion, destruction or anonymization of personal data when such data is no longer necessary or when the data owner withdraws consent; The right to request the suspension of the use of personal data in case the data is personal data that must be deleted or when such data is no longer necessary; The right to withdraw consent to the processing of data that the user has previously provided for the purposes specified. You can contact the Company to exercise the above rights according to the contact details specified by the Company. The Company will consider and notify the results of consideration of the request of shareholders, investors and/or those interested in the Company’s investment within a reasonable time frame under the law by sending an email to DPO@jubileediamond.co.th Or contact the head office of Jubilee Enterprise Public Company Limited, No. 179, Bangkok City Tower Building, 10th Floor, Sathorn Tai Road, Thung Maha Mek Subdistrict, Sathorn District, Bangkok 10120. You can also contact the company via Call Center at 02-625-1111, Monday-Friday, 9:00 a.m. - 6:00 p.m.
Amendments to this Policy
The Company may update this Policy from time to time to comply with applicable practices and laws or regulations, and the Company will notify you of any changes by posting the updated Policy to you through the Company's various communication channels.
Last modified: May 26, 2022