BIOTIME CCTV Privacy Notice

1. Who Operates the CCTV

Amintara Group Co., Ltd., operator of BIOTIME, is responsible for CCTV processing for which it determines the purposes and means, subject to applicable Thai data-protection law and any relevant building-management arrangements.

2. Purpose of CCTV

BIOTIME may use CCTV for legitimate purposes including protecting Members, guests, staff and other persons; maintaining safety and security; preventing and investigating theft, fraud, violence, harassment, unauthorized access or property damage; managing incidents and emergencies; protecting BIOTIME and third-party property; supporting the establishment, exercise or defense of legal claims; and complying with lawful requests or legal obligations.

3. Areas Under Surveillance

CCTV may operate in appropriate public or operational areas of the Club, including the entrance, strength-training area, cardio area, lounge and bar, as reasonably required for the stated purposes.

4. Areas Where CCTV Is Not Intended to Operate

BIOTIME will not intentionally install CCTV in toilets, showers, changing areas or other locations where individuals have a high and reasonable expectation of privacy. Camera placement should be designed to avoid unnecessary capture of private areas.

5. Information Collected

CCTV may capture images, video, date and time, location or camera identifier, movements, incidents and other visual information visible within the camera field. CCTV is not intended at initial launch to perform facial recognition or biometric identification.

6. Legal Basis

BIOTIME will process CCTV information under a legal basis permitted by applicable Thai law. Depending on the circumstances, this may include legitimate interests in safety, security, incident management and property protection; compliance with legal obligations; establishment, exercise or defense of legal claims; protection of vital interests in an emergency; or another lawful basis available under applicable law.

7. CCTV Is Not Marketing Consent

CCTV footage collected for safety or security is not collected for ordinary marketing merely because a person enters the Club. BIOTIME will not treat entry into a CCTV-monitored area as consent to use a person's image in advertising or promotional materials.

8. Notice at the Premises

BIOTIME will place appropriate short-form CCTV signage or notices at or before relevant monitored areas so individuals can understand that CCTV is operating and can access further privacy information.

9. Access to CCTV Footage

Access to CCTV recordings will be limited to authorized persons with a legitimate need, such as designated BIOTIME personnel, security personnel or service providers supporting the CCTV system. Access should be controlled and, where appropriate, logged.

10. Disclosure to Third Parties

CCTV information may be disclosed where lawful and necessary to building management, security providers, insurers, professional advisers, law-enforcement agencies, courts, regulators, emergency services or other parties where required or permitted by law, including for incident investigation, legal claims or protection of persons and property.

11. CCTV Service Providers

BIOTIME may use third-party providers to supply, host, maintain, secure or support CCTV systems. Such providers will be subject to appropriate contractual, confidentiality, security and data-protection requirements according to their role and applicable law.

12. Retention

CCTV recordings will be retained only for a period reasonably necessary for the stated purposes. BIOTIME's operational target should be a limited rolling retention period appropriate to security needs, unless footage must be preserved longer because of an incident, complaint, investigation, legal claim, regulatory request or other lawful reason. The final technical retention period will be documented in BIOTIME's internal CCTV procedure.

13. Incident Preservation

Where footage is relevant to an accident, security event, complaint, suspected misconduct, legal dispute or investigation, the relevant footage may be isolated from ordinary deletion and retained for as long as reasonably necessary to resolve the matter and satisfy applicable legal requirements.

14. Security Measures

BIOTIME will apply reasonable measures to protect CCTV data against unauthorized access, loss, alteration, disclosure or misuse. Measures may include restricted accounts, role-based access, secure storage, access logs, password or authentication controls, vendor controls and procedures governing export or sharing of footage.

15. Audio Recording

BIOTIME does not intend to use CCTV for continuous audio recording at initial launch. If audio recording is introduced, BIOTIME will assess its necessity and legal basis and update notices and controls before implementation as required.

16. Facial Recognition and Biometrics

BIOTIME does not intend at initial launch to use CCTV footage for facial-recognition identification or to create biometric templates. Any future introduction of biometric surveillance would require a separate legal, necessity, proportionality and sensitive-data assessment before implementation.

17. International Transfers

If a CCTV service provider stores or accesses footage outside Thailand, BIOTIME will assess and implement any cross-border transfer safeguards required under applicable Thai data-protection law.

18. Data Subject Rights

Subject to applicable law, practical limitations and the rights of other persons appearing in footage, an individual may have rights concerning personal data captured by CCTV, including rights of access, correction where relevant, deletion or restriction in applicable circumstances, objection to certain processing, and complaint to the competent authority. Some requests may be limited where disclosure would adversely affect the rights of others, security, investigations or legal obligations.

19. Requests for CCTV Footage

A person requesting access to CCTV footage should provide sufficient information to enable BIOTIME to identify the relevant recording, such as approximate date, time, location and identifying details. BIOTIME may verify identity and may redact, blur, withhold or otherwise protect images of other persons where necessary and lawful.

20. Law-Enforcement Requests

BIOTIME may preserve or disclose CCTV information in response to a lawful request from police, courts, regulators or other competent authorities. BIOTIME may also disclose footage where permitted by law to prevent or investigate serious incidents or protect legal rights.

21. Data Breaches

Any unauthorized access, loss or disclosure involving CCTV information will be assessed under BIOTIME's personal-data incident procedures. Where notification obligations arise, BIOTIME will act in accordance with applicable Thai law.

22. Relationship to Other BIOTIME Documents

This Notice supplements BT-PP-1.0. Club conduct, photography and access rules are addressed in BT-CR-1.0. Acceptance of Membership Terms is not consent to CCTV processing; CCTV processing is assessed under the appropriate legal basis.

23. Changes to This Notice

BIOTIME may update this Notice when camera locations, technology, providers, retention practices, law or processing purposes materially change. The current version and effective date will be identified.

24. Language

This Notice is available in Thai and English. Both versions are intended to communicate the same substantive information. If interpretation differs, the Thai version prevails to the extent required or permitted by Thai law.

25. Contact

Questions, requests or complaints concerning CCTV should be directed through BIOTIME's official privacy/contact channels published on biotime.club.