Privacy Policy | Pacific Prime Thailand

This Privacy Policy has been written to explain to you, users of our websites and clients, what data we collect, how we use it, and our adherence to both local and international regulations such as the GDPR.

The terms ‘we’, ‘our’, and ‘us’ used in this Privacy page refer to Pacific Prime Consultants limited; more commonly referred to as Pacific Prime Thailand, and hereinafter as Pacific Prime. Find our company contact details using this link.

Pacific Prime's stance on data collection, processing, and protection

In all things related to data collection and protection, we strive to implement and follow modern best practices. Where possible we have adopted practices that ensure we are compliant across borders. The information contained within this privacy policy meet or exceed the following generally accepted data principles:

Personal data is processed fairly and legally - We do not collect or process any data unless it is contractually required or it is necessary by our partners.
Personal data shall be obtained only for one or more specified and lawful purposes - As noted above and explained through the document, Pacific Prime only collects and processes data when we need to.
Personal data shall be relevant - Data collected by Pacific Prime is only what is needed, and nothing else. Any requests made by clients or otherwise are followed through immediately, or within the next business day.
Personal data shall be accurate - All data collected by Pacific Prime is deemed to be accurate and any changes are updated as soon as physically possible.
Personal data shall be kept only for as long as it serves a purpose - All data stored by Pacific Prime is kept only as long as needed or legally required.
Personal data shall be processed only in accordance with local and international law - All data collection, processing, and storage is done in a way that it is compliant with local requirements where we have offices and international regulations such as the GDPR.
Appropriate technical and security measures must be taken to secure personal data - Pacific Prime employs robust IT solutions and standard operating procedures that ensure all personal data is secure and only available to those who use it.
Personal data shall only be shared as necessary - Pacific Prime does share data, only as necessary, with other Pacific Prime offices. Any transfer of data is done utilizing secure methods. We will also only share data with third parties as is contractually necessary or legally required. We will not sell any of this data.

How we meet these policies is explained throughout this document.

What is the PDPA?

The PDPA is the most comprehensive Thai data privacy law to date, as it covers the rights of users whose data is collected, processed, and held for a specific business purpose. This defining act helps to safeguard personal (general and sensitive) information and ensure businesses operate accordingly and within strict, specific guidelines set by the legislation, and is compliant with other regulations internationally, such as the EU’s GDPR.

What is the PDPA short for?

The PDPA is short for Personal Data Protection Act B.E.2652 of the Kingdom of Thailand, which has a total of seven chapters and 96 sections (all of which are subject to change) concerning privacy regulation. Although it was published in the Royal Gazette in May 2019, some chapters have been delayed to give the public and private sector time to prepare internal processes and ease the financial burden as a result of the COVID-19 pandemic.

Suspended from enforcement are Chapter 2 involving the protection of personal data, Chapter 3 related to the use or disclosure of personal data, Chapter 5 linked with complaints, Chapter 6 associated with civil liability, and Chapter 7 concerning penalties. In addition to this, Section 95 of the transitional provision is also suspended, which involves personal data collected before the act took effect.

The effective date for all Chapters to come into effect is on 1st June, 2022.

(Take note: This section, as well as other sections on this page, is subject to change as new updates are released between now and 1st June, 2022.)

What data is being collected?

As an insurance broker, Pacific Prime is contractually obligated to collect and retain certain personal data of both potential and existing clients. The data collected reflects what is required by insurers in order for the insurer to offer quotes, fulfill applications, underwrite, and enable coverage.

The personal data collected can include some or all of the following:

Name (first, middle, and last) - All people to be covered by an insurance plan.
Address (work, or home) - Of the primary policy holder.
Contact details (Phone number, email) - Of the primary policy holder or spouses.
Age - All people to be covered by the plan
Gender - All people to be covered by the plan
Nationality - All people to be covered by the plan
Job title - Of the primary policy holder
Family structure - If a family is applying for cover
Medical history - Personal - Of the primary policy holder
Medical history - Family - Of all people to be covered by the plan
Insurance purchase, coverage and claims history - Primary policy holder.
Lifestyle information - Of All people covered by the plan.
Details related to method of payment (including credit card and bank account information) - Of the primary policy holder as well as any spouses.
Preferences related to the purchase of insurance products and services - This applies not only to potential or current clients that we deal with directly, but also family members that they act on the behalf of.

Collection of data from businesses

The above list also applies to businesses that Pacific Prime sells to. For businesses additional data might also be requested by the insurer. This could include:

Employee data of all types listed above
Business registration and ownership information
Business tax registration record
Employee salary record - for life/disability plans only

Collection of data from children

Pacific Prime sells insurance cover to families. This means that a child's data may need to be collected, as is contractually required by an insurer. With all data collected for children under 18, Pacific Prime will contact the parents or guardian of the children to first gain consent and to explain what data is being collected and why.

In situations where we are dealing with a minor (any person under the age of 18) as the primary policy holder (e.g., a student going overseas contacts us looking for insurance) we will contact the parent or guardian of the minor and ensure that consent for requested data is provided. Parents or guardians will be involved in ALL communication and any decisions made.

Who collects data at Pacific Prime?

Officially employed Pacific Prime staff are the only persons approved to gather, handle, maintain, and use users’ personal data. Generally this will be handled by people on our sales staff, but such data can also be handled by staff in Pacific Prime’s renewals, claims, administration, accounting, marketing, and client support departments, or by individuals among our principals and leadership.

How is data collected by Pacific Prime?

All data gathered by Pacific Prime is furnished by users of their own accord as long as their explicit consent is provided (see section below). You reserve the right to question what data is collected and why. User data may be collected across various mediums. Mediums where Pacific Prime collects data include:

Insurance quote forms on our website - Certain data such as age of those to be covered, location, nationality, name, and phone or email are required in order to develop a personalized quote and enable our Sales team to contact you should you have questions or want to apply for insurance cover.
Email - This is the primary way application data is collected. Data collected by this medium will only be collected as necessary/required/requested by an insurer or as contractually required by law.
Application forms from the insurer, or ones created by Pacific Prime on behalf of an insurer, and other written documents - Only data listed in these forms will be collected. Data that is not necessary will not be requested.
Telephone calls and in-person verbal communication - Data that is not necessary will not be requested. Our advisors will plainly state what data they need and why it is necessary.
Text messages - This includes SMS, WeChat, WhatsApp, Facebook, and other chat/messaging apps. Data collected will only be what is necessary to furnish information requested by the client.
Smartphone applications - Data collected here will only be what is contractually necessary.
Online forms - Data collected here is for marketing purposes and will never be shared with third parties unless consent is provided by the data holder, or is legally requested by a government.

Consent to collect data

By using this website, you consent to the collection and use of your personal data as described in this document. This consent is deemed to be entirely voluntary with data only being collected when contractually necessary, as required by law, or for marketing purposes.

Where required by applicable law, we will seek your explicit consent to collect, process, and use the personal data described in this document. In all cases, data requested will only be what you freely give. You maintain the right to refuse to provide your data along with the right to request to view or delete the data we have collected from you at any time.

It is important to note however that refusal to provide data that is contractually necessary, or data that you are legally obligated to cover will result in our inability to offer you our products or services. The use of this website will also not be possible.

If you would like to change/modify your consent please follow the contact information in the What control do I have over data and how do I change my consent? section of this document.

Why does Pacific Prime collect data?

Pacific Prime gathers information from users for two purposes:

Contractually necessary purposes – In order to apply for an insurance policy with an insurance provider, a user will need to provide information as required by a particular insurance company’s application requirements. Any data not required by an insurer will not be requested.
Marketing purposes – Aside from information directly relevant to insurance providers and products, the only other information used by Pacific Prime is purely for marketing purposes. This will only include contact details (email, and phone) and basic personal information (name), and will never include any type medical information.

How does Pacific Prime use collected data?

Pacific Prime uses data gathered from users to facilitate the sales, purchase, underwriting, payment, administration, use, and renewal of various insurance and financial products and services. We may also use personal data for marketing purposes related to the sale, purchase, underwriting, payment, administration, use, and renewal of various insurance and financial products.

In all cases, consent will be required. You can change your consent/Request to view your data that we have collected at any time by following the information in the What control do I have over data and how do I change my consent? section below

Does Pacific Prime share data?

Any user data collected by Pacific Prime is shared only internally within our offices, and with relevant licensed insurance companies, insurance agents, third party administrators, and third party service providers, as it directly applies to the wishes of the user. Any personal data regarding a particular user is also available to them upon request. We may also share requested user information with governmental authorities as required by law and local regulations. Please see the Office of Insurance Commission’s privacy statement: https://www.oic.or.th/sites/default/files/privacy_policy.pdf.

Pacific Prime does not share user data with any third parties outside of relevant insurance companies, insurance agents, third party administrators, third party service providers, or governmental bodies, and does not sell user data under any circumstances.

How long does Pacific Prime store data?

Pacific Prime stores data for as long as a user is a client or can reasonably be considered a potential customer without having notified us of their intention to opt out of any marketing communications. Beyond this, users that purchase products or services through Pacific Prime will have their data stored for up to seven years following the end of their business with us, as such data may be needed for reasons related to taxation, governmental, and financial compliance.

What control do I have over data and how do I change my consent?

Users can be notified of and amend any of their data collected by us, as well as opt out of receiving any marketing promotions from us. You also maintain the right to be forgotten (request that Pacific Prime delete all of your personal data) To do so, please send notification to Pacific Prime at the following address:

Pacific Prime Data Protection Officer

9th floor (9D, E), President Tower, 973 Phloenchit Road, Lumpini, Pathumwan, Bangkok 10330

Alternatively, users can contact us at [email protected], or by using the page found at this link.

Failure to notify us of a desire to ‘opt out’ of marketing promotions will be interpreted as an agreement to allow Pacific Prime to continue using your personal data for voluntary marketing purposes.

Is this likely to affect me negatively?

Pacific Prime only collects data provided to us directly by users, and only shares said data internally and with relevant third parties as instructed by users. We also maintain cutting edge data protection practices to ensure the proper and safe handling of user data, both internally and externally.

Again, we do not sell user data, or share it with third parties not directly applicable to the sales, purchase, underwriting, payment, administration, use, and renewal of insurance products for the user.

As such, it is highly unlikely that our gathering, storage and sharing of user data will have any negative effect on users.

Is Pacific Prime's data collection policy compliant?

All of Pacific Prime’s data collection, protection, and usage policies are fully in line with international regulations, including the European Union’s General Data Protection Regulation and Thailand’s impending Data Protection Bill. Furthermore, all users have the ability to view and alter any submitted user data. Thus, the Pacific Prime Privacy Policy is unlikely to cause objections or complaints.

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