Privacy Policy

Privacy Notice
Jadepay Co., Ltd.

Jadepay Co., Ltd. ("Company"is committed to safeguarding personal data and respecting the privacy of its customers. This Privacy Notice is designed to inform customers of the Company regarding the policies related to the collection, use, and disclosure of personal data of natural persons ("you"") in compliance with the Personal Data Protection Act B.E. 2562 (2019) ("PDPA"), as well as other applicable laws and regulations.

This Privacy Notice will inform you of the methods by which the Company collects, uses, or discloses your personal data, the types of data involved, the purposes for such activities, as well as the duration for which data is retained, the disclosure of personal data to third parties, your rights, the confidentiality and security measures in place to protect your personal data, and how you may contact the Company.

This Privacy Notice applies to the following individuals:

(1) Customers of the Company

 Individual Customers:: Former and current customers of the Company who are natural persons.

(2) Non-Customers of the Company

This includes natural persons who do not have products or services with the Company but whose personal data may be collected, used, or disclosed by the Company, such as investors, individuals making payments to or receiving payments from the Company's customers, visitors to the Company's website or applications, individuals using services at the Company’s offices, guarantors or security providers, ultimate beneficiaries, directors or authorized representatives of legal entities using the Company’s services, debtors of the Company’s customers, professional advisors, as well as directors, investors, and shareholders of the Company and authorized representatives of such individuals, and any individuals involved in transactions with the Company or its customers.

Please note that links on the Company’s platforms may lead you to external third-party platforms. Once you access a third-party platform, the processing of your personal data will be governed by the privacy policy of the respective third party. Therefore, the Company recommends that you review and understand the privacy policy of such third parties when you use their platforms.

1. How the Company Collects, Uses, or Discloses Your Personal Data

The Company will collect, use, or disclose your personal data only when necessary or when a lawful basis exists for doing so. This includes circumstances where data collection, use, or disclosure is required for compliance with legal obligations, the performance of a contract you have entered into with the Company, the legitimate interests of the Company, activities conducted with your consent, and/or under other lawful grounds. The purposes for which the Company collects, uses, or discloses personal data include but are not limited to the following:

1.1. The Company's Legal Obligations

As the Company operates under regulatory oversight and is required to comply with applicable laws and regulations, it must collect, use, or disclose your personal data for various purposes to fulfill its legal and regulatory obligations with governmental authorities and/or supervisory bodies overseeing the Company. These purposes include, but are not limited to, the following:

(a) To comply with the Personal Data Protection Act and its amendments.

(b) To comply with laws (e.g., laws related to financial institutions, securities and exchange laws, anti-money laundering laws, counter-terrorism financing laws, laws against the proliferation of weapons of mass destruction, and other laws applicable to the Company, both domestically and internationally). This includes conducting identity verification, background checks, credit checks, Know Your Customer (KYC) procedures, Customer Due Diligence (CDD), and other checks, including checks against public databases maintained by regulatory authorities and/or lists of designated persons. It also involves ongoing activities to ensure compliance with relevant laws.

(c) To comply with regulations and/or orders from competent authorities (e.g., court orders, orders from governmental bodies, supervisory authorities overseeing the Company, or authorized officials).

1.2. Contracts you have entered into with the Company

The Company will collect, use, or disclose your personal data based on requests and/or agreements you have entered into with the Company. This includes, but is not limited to, the following purposes:

(a) To process your requests prior to entering into a contract with the Company, assess and approve services or products, deliver products and/or services to you, provide advice and manage products and/or services (including depositing payments, loan repayments, or withdrawals). This also includes any actions necessary for the Company’s operations or services, without which the Company's operations or services may be adversely affected or rendered unfair or discontinuous.

(b) To verify your identity for any transactions.

(c) To process your instructions (e.g., executing your orders, processing requests related to loans and credit facilitation, responding to your inquiries or suggestions, or resolving your complaints).

(d) To provide investment services via internet networks (online investments), mobile applications, and other online product platforms.

(e) To monitor or record your transactions, rights, and benefits.

(f) To prepare reports (e.g., transaction reports requested by you or internal reports of the Company).

(g) To notify you of transactions.

(h) To recover outstanding debts you owe the Company (e.g., in cases where you have not repaid loans and/or unpaid fees).

(i) To process or enter into transactions and/or process payments or receipts, such as handling payment transactions, completing transactions, debt settlements, billing, account reconciliation, conducting activities to manage relationships with the Company, and performing account registration processes in connection with your account as the Company’s customer.

(j) To enforce the Company’s legal or contractual rights.

(k) To provide IT support and helpdesk services, create and maintain your user credentials and accounts, manage access to systems you are authorized to access, and deactivate inactive accounts.

(l) To occasionally offer you investment products (including third-party investment products that may interest you) and manage all matters related to such investment products.

1.3. The Company's Legitimate Interests

The Company may rely on its legitimate interests as a legal basis for collecting, using, or disclosing your personal data, taking into account the Company’s or other persons’ benefits and your fundamental rights concerning personal data. These purposes include, but are not limited to, the following:

(a) Managing the Company’s business and the operations of SCBX Financial Business Group, such as governance, risk management, financial and accounting management, internal audits, fraud prevention, anti-money laundering, counter-terrorism financing, addressing misconduct, or preventing other criminal activities. This includes verifying the credibility of individuals related to the Company’s corporate customers, even if such verification is not mandated by law, as well as identifying you to prevent such crimes.

(b) Managing the relationship between the Company and you, including customer care, satisfaction assessment, and complaint handling.

(c) Ensuring security measures such as CCTV recordings, visitor registration, card exchanges, and/or capturing the images of individuals entering the Company’s premises.

(d) Developing and improving the Company’s products, services, and operational systems to enhance service standards and/or better meet your needs while offering products, services, and benefits tailored to you. If you wish to opt out of receiving such offers, you may do so via the Easy Invest Application.

(e) Recording images and/or audio related to meetings, training sessions, seminars, recreational activities, or marketing events.

(f) Ensuring the continuity of the Company’s business operations.

(g) Managing claims and disputes, initiating legal proceedings, and conducting relevant legal processes.

(h) Contacting you prior to entering into a contract with the Company.

(i) Assessing the suitability and qualifications of individuals, submitting proposals for bidding and tender processes, and entering into contracts with you.

(j) Preventing security risks, such as monitoring network activity logs, identifying security incidents, conducting data security assessments, and other protective measures against malicious, fraudulent, or unlawful activities.

(k) Complying with applicable foreign laws.

(l) Managing the Company’s structure, including data storage, internal controls, business operations, and compliance with the Company’s policies and processes. This includes risk control, security, auditing, finance and accounting, system management, and business continuity planning.

(m) Conducting research, planning, and statistical analyses, such as data analytics, evaluations, surveys, and reporting on the Company’s products and/or services and your behaviors to identify business opportunities for the Company.

(n) Organizing promotional campaigns, conferences, seminars, and company visits.

(o) Facilitating accounting audits conducted by auditors.

(p) Engaging legal advisors, financial consultants, and/or other consultants appointed by you or the Company.

(q) In cases of sales, transfers, mergers, reorganizations, or similar events, the Company may disclose and transfer your personal data to one or more third parties as part of such transactions.

(r) Maintaining and updating customer records and directories (including your personal data) and storing contracts and related documents that may reference you.

(s) Complying with reasonable business practices, such as management, training, audits, reporting, risk control or management, statistical analysis, trend planning, revenue sharing calculations, customer segmentation, or similar activities. This includes implementing business controls to ensure smooth business operations and resolving issues in the Company’s IT systems to enhance security and ensure the development, implementation, operation, and maintenance of the Company’s IT systems.

1.4. Your Consent

In certain circumstances, the Company may request your consent to collect, use, or disclose your personal data to provide you with the best possible benefits and/or to deliver services tailored to your needs. This includes, but is not limited to, the following purposes:

(a) Collecting, using, or disclosing sensitive personal data (e.g., using a photograph of your national identification card, which contains sensitive personal data such as religion and/or blood type, and criminal records) for identity verification and Know Your Customer (KYC) procedures prior to transactions.

(b) Collecting and using your personal data and any related information for research and analysis purposes to enhance products and services that genuinely meet your needs and/or to contact you to offer personalized products, services, and benefits.

(c) Transmitting or transferring your personal data and sensitive personal data to foreign countries that may not have adequate personal data protection standards (except where permitted under other lawful grounds as stipulated by the PDPA, or where consent is not required).

(d) In cases where you are a minor, incompetent, or quasi-incompetent person, obtaining consent from your parent, guardian, custodian, or curator, as applicable (except where the PDPA allows processing without consent).

(e) Disclosing your personal data and any related information to the financial business group companies listed on the Company’s website and the Company’s trusted business partners for the following purposes: (1) Researching, conducting statistical analysis, developing, and analyzing products, services, and benefits that meet your needs. And (2) Contacting you to offer or provide suitable products, services, and benefits.

(f) Undertaking other actions requiring your consent.

1.5. Other Legal Grounds

In addition to the aforementioned legal bases, the Company may collect, use, or disclose your personal data under the following legal grounds:

(a) Preparing historical or archival records for the public interest, or for purposes related to research or statistics.

(b) Preventing or mitigating harm to the life, body, or health of individuals.

If the personal data the Company requests from you is necessary for compliance with legal obligations or the performance of a contract with you, the Company may be unable to provide (or continue to provide) certain products or services in whole or in part if you fail to provide such personal data when requested.

2. Personal Data Collected, Used, or Disclosed by the Company

The types of personal data collected, used, or disclosed by the Company vary depending on the scope of products and/or services you may have used or expressed interest in. This includes both general personal data and sensitive personal data, as outlined below:

Type of Data	Examples of Personal Data
Personal Details	 Title (e.g., Mr., Ms.)  First Name, Middle Name, Last Name, Alias (if any)  Gender  Date of Birth  Age  Education  Marital Status  Nationality  Spouse’s Information
Contact Details	 Mailing Address  Email Address  Telephone Number  Mobile Phone Number  Fax Number  Name of the Customer's Representative or Authorized Agent  Social Media Accounts (including profile photos and identifiers used for electronic communication)  Business Contact Address  Business Contact Phone Number
Identification and Verification Details	 Photograph of National Identification Card  National Identification Number  Passport Information  Driver’s License  Signature  Tax Identification Number  Household Registration
Employment Details	 Occupation  Employer Details  Job Title  Salary or Income  Compensation  Job Position  Bonuses  Workplace
Financial Details and Information About Your Relationship with the Company	 Products and/or services you are using  Channels and methods of interaction with the Company  Customer status, creditworthiness, payment history, and transaction records  Information related to your transactions  Account name, account number, and account type  User account history  Income and expenses  Payment details  Service commencement date  Account balance  Credit limits and approved credit amounts  Timestamp  Transaction logs
Market Research and Marketing Data	 Customer surveys  Information and opinions provided during market research (e.g., your answers to questions, survey responses, requests for feedback, and participation in research studies)  Details of services you have received and your requirements  Conclusions about you derived from interactions with the Company  Communication preferences and the content or details of communications between you and the Company
Geographical Data, Device, Software, and Technical Details	 Channels used to access services  Your GPS location  Computer IP address  Technical specifications and unique identifiers (e.g., web beacons, logs, device ID, device model and type, network, connection details, access data, single sign-on (SSO) details, login logs, access dates and times, session durations, cookies, login information, search history, browsing data, browser types and versions, time zone settings and locations, language settings, browser plugin types and versions, operating systems, platforms, and other technologies used on your devices).
Verification Data	 Data used for verification purposes, such as Know Your Customer (KYC) information and Customer Due Diligence (CDD) processes.  Data related to risk management or the detection of money laundering and counter-terrorism activities.
Access, Service Requests, and User Account Details	 Data related to system access, investment transactions via the Company’s internet network, and applications.  User account identifiers.  Usernames and passwords.
Usage Details	 Data about your use of the Company’s websites, platforms, products, and services.  Data regarding your interactions with and responses to the Company’s advertisements (including content viewed, links clicked, and functions used).
Security-Related Information	 Photographs.  Physical descriptions.  Suspicious activity or anomalies detected.  Still or video footage from CCTV systems.  Video recordings.
Sensitive Personal Data	 Religion, as indicated on your national identification card.  Blood type, as indicated on your national identification card.  Criminal records.
Other Data	 Records of interactions and communications between you and the Company, regardless of format or method, including but not limited to phone calls, emails, chat messages, and communications via social media platforms.  Any information you provide to the Company through any channel.

3. Sources of Your Personal Data

Generally, the Company collects personal data directly from you. However, in some cases, the Company may obtain your personal data from other sources in accordance with the Personal Data Protection Act (PDPA). Personal data collected from other sources may include, but is not limited to, the following:

(a) Data received from companies within the financial business group, business partners, and/or other entities with which the Company has legal relations.

(b) Data provided by individuals associated with you (e.g., your family, friends, or referees).

(c) Data obtained from corporate customers where you act as a director, authorized representative, agent, assignee, or contact person.

(d) Data received from service providers, authorized officers and agencies, or third parties (e.g., your representatives, employers, sponsors, or third parties involved in providing services to you, or any individual acting on their behalf who may provide information about you to the Company).

If you provide the Company with personal data of another individual during a transaction or in any other circumstance, you must inform that individual about the collection, use, and disclosure of their personal data, as well as their rights under this Privacy Notice. Additionally, you must obtain consent from such individuals (if required) or rely on other legal grounds before providing their personal data to the Company.

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