Privacy Policy

Privacy Policy for Customers of
CP ALL Laos Company Limited

CP ALL Laos Company Limited values your privacy and is committed to safeguarding your Electronic Data with which you have entrusted us. CP ALL Laos Company Limited has formulated this privacy policy (this “Privacy Policy”) to inform you, as a data owner, of the objectives and details for collection, use, storage and/or disclosure of your Electronic Data and your legal rights.

1. Definitions  

In this Privacy Policy, the following have the meanings set out below: 

Company means CP ALL Laos Company Limited.   
Customer(s), you or your means a customer, a buyer, or a client using the Website, products or other services of the Company and any business partner(s) of the Company include but not limited to supplier, vendor.   
Data Protection Law  means the Law on Protection of Electronic Data (№ 25/NA, 12 May 2017) including any existing or future amendments or replacement law.  
Data Protection Guidelines means the Guidelines on the Implementation of the Law on Electronic Data Protection (№ 2126/MoPTC, 8 August 2018) including any existing or future amendments or replacement law.  
Electronic Data means the General Data and Specific Data as classified under the Data Protection Law.  
General Data means the generic data of a Customer as described in Section 2.1.1 herein.   
Lao PDR Data Privacy Laws means collectively, the Data Protection Law and the Data Protection Guidelines.   
Processing of Electronic Data means the collection, use, storage, disclosure and/or transfer of Electronic Data by the Company and/or other authorised recipients of Electronic Data as provided in Section 4 herein.   
Specific Data means the personal data of a Customer as described in Section 2.1.2 herein.  
Specific Data Officer means the officer(s) appointed by the Company to perform and act as the specific data officer as contemplated in the Data Protection Law.   
Third Party Data Processor means an individual or company who collects, use, store, disclose or transfer Electronic Data pursuant to the instructions given by or on behalf of the Company.   
Website means any website owned or operated by CP ALL Laos Company Limited in respect of its Lao PDR operations.  

2. Collection, Use, Storage, Disclosure and/or Transfer of Electronic Data 

Sources of Electronic Data Through your engagement with CP ALL Laos Company Limited, the Company will collect, use, store, disclose and/transfer your Electronic Data for the purposes of the Processing of Electronic Data in compliance with Lao PDR Data Privacy Laws in the following ways:  

2.1 Categories of Electronic Data 

Your Electronic Data, whether directly given to the Company or indirectly received from third parties, shall be categorized as either: 

2.1.1 General Data which includes name and surname, national identification card number, passport number, photos, gender, date of birth, age, address, telephone number, email address, etc.; or 

2.1.2 Specific Data which includes financial information and technology information.  

2.2 Consent of the Customer for the collection, use, storage, disclosure and/or transfer of Electronic Data  

The Company is required to obtain the consent of the Customer for the Processing of your Electronic Data. In the case of changes on use and purpose of Processing of Electronic Data, the Company will inform the Customer of such changes and obtain his/her consent. This also applies to any international disclosure and/or transfer of Electronic Data which will be made in accordance to the Lao PDR laws.  

Notwithstanding the above, the Company will not be required to obtain the consent of the Customer if Electronic Data is requested by a Lao PDR State authority in accordance with the Lao PDR laws.  

2.3 Sources of Electronic Dat

2.3.1 The Company may collect Electronic Data from you, in the case where you are using the Company’s services or providing your Electronic Data through the Website or though other available channels, such as customer inquiries, feedback or complaints. 

2.3.2 The Company may collect your Electronic Data from third parties such as Lao PDR State authorities, business partners or other reliable websites, etc.  

2.4 Retention Period and Deletion of Electronic Data

The Company will collect and retain your Electronic Data for a necessary period of time. If it is no longer necessary to use your Electronic Data for the purposes of Processing of Electronic Data, the Company will cease Processing of Electronic Data and at its election, delete or return any data or document related to Electronic Data to you, save and except in the case where the Company is required to maintain such Electronic Data in accordance with the applicable Lao PDR laws. If it is impractical to return Electronic Data to you, the Company will delete, destroy or anonymize such Electronic Data.  

In addition, the Company will delete your Electronic Data (i) upon receiving your request for such deletion; (ii) if Electronic Data impacts to Lao PDR national security, peace, and social order, or which slanders other individuals. You will be notified of such deletion, unless otherwise determined by the Lao PDR laws.  

3. Purposes of Processing of Electronic Data 

The Company will process your Electronic Data for the following purposes:  

3.1 For membership registration or customer account opening; 

3.2 For entering into agreements for the sale and purchase of products and services, construction, hire of work, and other relevant agreements; 

3.3 For preparation and delivery of customer orders; 

3.4 For marketing activities; 

3.5 For the recruitment and employment process;  

3.6 To enhance security measures for employees, customers, and third parties who enter the building and surrounding areas, such as office buildings and 7-11 stores, by installing CCTV cameras; and 

3.7 For any other purposes related to your interests as our Customer/ Employee.  

4. Disclosure and/or Transfer of Electronic Data 

The Company will disclose and/or transfer your Electronic Data in compliance with the purposes to the following persons:

4.1 The Company’s affiliates. Whereby the Company discloses your Electronic Data to its parent company (CP ALL Public Company Limited) and/or 7-Eleven convenience stores based in the Lao PDR and other jurisdictions, as well as to their employees or authorised person(s) to the extent necessary in compliance with the purposes set out above; 

4.2 Service providers and a Third Party Data Processor which the Company appoints or authorises to manage or process Electronic Data; 

4.3 A competent State authority under the Lao PDR laws;  

4.4 State enterprises or private entities such as commercial banks, financial institutions, insurance companies, hospitals, etc.; 

4.5 Business partners of the Company such as freight forwarders, other related vendors, contractors, contractual parties related to 7-Eleven business operations and providing services to you, etc.;  

4.6 Company’s consultants for providing advice on business operations such as accounting auditors, external auditors, experts, legal consultants, attorneys, etc.; or  

4.7 Other person(s) or business sector(s) in which you had given consent to disclose your Electronic Data.  

5. Your rights as the Data Owner 

5.1 You have the rights to obtain a copy of your Electronic Data and be informed of the sources of Electronic Data. 

5.2 You have the rights to request the Company to correct and revise your Electronic Data in the case where Electronic Data is found to be inaccurate, outdated or incomplete.  

5.3 You have the rights to withdraw your consent for the Company to Processing of Electronic Data, at any reasonable time, unless otherwise determined by the Lao PDR laws or if you are bound by any existing legal or contractual obligation such as an employment contract with the Company. Where you choose to withdraw your consent, you may not be able to receive services from or conduct transactions with the Company, and the extent of the Company’s ability to provide services to you will be restricted.  

5.4 You have the right to receive Electronic Data concerning yourself from the Company. The Company will arrange such Electronic Data to be in the format which is readable or commonly used by ways of automatic tools or equipment and can be used or disclosed by automated means. You are also entitled to request the Company to transfer Electronic Data to other third parties (if it can be transferred by automated means). 

5.5 You have the rights to object to the Processing of Electronic Data, at any reasonable time, where the Processing of Electronic Data are for the purposes other than those provided in Section 3 herein. 

5.6 You have the rights to request the Company to erase or destroy or anonymize Electronic Data in accordance with Section 2.4 herein.

5.7 You have the rights to request the Company to restrict the use of Electronic Data in the following instances:

(a) When the Company is in the process of updating Electronic Data to ensure that it accurate, up-to-date, complete and not misleading; 

(b) Where Electronic Data will be erased or destroyed because it has been unlawfully collected, used, stored, disclosed or transferred; or  

(c) Where it is no longer necessary to retain such Electronic Data for its intended purpose, but you require it to be retained for the purpose of establishment, compliance, or the exercise or defense of legal claims. 

5.8 You have the right to petition State authorities in accordance with the Lao PDR Data Privacy Laws if the Company or its employees or Third Party Data Processor(s) do not comply with the Lao PDR Data Privacy Laws.

5.9 If you wish to exercise the above rights, please contact us at datamanager_laos@cpall.co.th.  

6. Security Measures for Storing Electronic Data 

The Company is committed to protecting your Electronic Data. The Company will provide security measures including a safe and appropriate system for collecting, using, storing, disclosing or transferring Electronic Data to prevent your Electronic Data from accidental loss, unauthorized access, destruction, misuse, inappropriate storage methods, unauthorized change or disclosure. 

The Company implements security measures which include operational and physical safeguards, and technical protection measures over the access or control of Electronic Data usage which consist of the following:  

6.1 Access control to Electronic Data and storage devices and to the Processing of Electronic Data considering the usage and security; 

6.2 Determine permission granted to a third party in accessing Electronic Data; 

6.3 Determine roles and responsibilities of users to prevent unauthorized access, disclosure, cybercrime, copying, or to prevent theft; and 

6.4 Provide access tracing, alteration, disposal, or transmission of Electronic Data. 

7. Link to Third Party Website Disclaimer

The Website may contain links to third parties’ websites. The third parties may collect information of your usage of their services. The Company accepts no liability over Electronic Data collected via the third parties’ websites. You are responsible to verify the privacy policy, products and services provided by the third parties. 

8. Application of this Privacy Policy  

This Privacy Policy applies to all Electronic Data collected, used, stored, disclosed and transferred by Company, and in which the Company has obtained consent from you prior to carrying out the processing activity, including future collection of Electronic Data and for use, storage and disclosure to the third parties within the scope of this Privacy Policy. 

9. Review of this Privacy Policy  

The Company and its relevant working units will review this Privacy Policy at least once a year. The Company may consider rectifying or revising this Privacy Policy from time to time, as deemed appropriate and permitted by the Lao PDR laws (including the Lao PDR Data Privacy Laws). In case of rectification or revision of, or change in this Privacy Policy, the Company will announce the current policy on the Website.  

10. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with Lao PDR laws and Lao PDR courts have the jurisdiction to consider any dispute that may arise. 

11. Contact Informatio

Any question or concern regarding this Privacy Policy, the exercising of your rights, or have reasonable reasons to believes that Electronic Data has been misused, please contact the Company by the following channels: 

CP ALL Laos Company Limited   602 Khum Pheng Muang Road, Unit 34, Phothanneua Village, Xaysettha District, Vientiane, Lao PDR E-mail address: datamanager_laos@cpall.co.th  
Specific Data Officer   E-mail address: datamanager_laos@cpall.co.th