Privacy Policy
True Money Company Limited (the “Company”) realizes the importance of the privacy and the personal data protection of the Company’s customers and clients (collectively called as “you”). Thus, the Company has established the Privacy Policy and to notify you regarding the Company’s guideline for the collection, use and disclosure of personal data in order to enable you to confidently use electronic money service via TrueMoney Wallet application (the “Application”), payment dealer service, money transfer service via electronic methods and other services as approved by Bank of Thailand, which are currently available and may be available in the future (collectively called as the “Services”).

Personal Data
“Personal Data” means the information relating to a person, which enables the identification of such person, whether directly or indirectly, but not including the information of the deceased persons in particular, such as name-surname, identification card number, address, telephone number, financial transaction.

Personal Data may consist of sensitive information and at risk of being treated unfairly (Sensitive Personal Data) such Personal Data includes but not limited to biometrics data, data relating to religious.

In this regard, such Personal Data includes any information provided by you to the Company and/or being in the Company’s possession and/or lawfully collected by the Company from any other sources or any other persons.

In case where necessary for the Company to collect, use or disclose your Personal Data which is out of the scope as specified in this Privacy Policy, the Company will inform you regarding such different characteristics at the time or prior to the collection, use or disclosure of your Personal Data.

By using the Services, it is considered that you have read and understood this Privacy Policy.

Type of Personal Data Collected, Used or Disclosed by the Company
• Information on identification card, passport and/or other evidence issued by government authorities such as identification card number, name, surname, name prefix;
• Necessary contact information such as contactable address, telephone number, e-mail;
• Particular personal characteristics such as status, biometrics data;
• Education and/or career information;
• Financial information such as records of transactions made through TrueMoney Wallet accounts or other Services, credit card information, deposit account information;
• Information relating to your devices and usage behaviors, including but not limited to unique device identifier, IP address, mobile device operating systems, mobile network service provider, location, cookie.

For the necessity of providing additional services apart from fundamental Services or the collection, use, disclosure of Sensitive Personal Data other than those specified above, the Company will perform the processing under legal basis as prescribed by law only. In this regard, the Company will inform the purpose and type of Personal Data required to be collected, used or disclosed prior to or at the time of such processing.

Basis of the Collection, Use and Disclosure of your Personal Data and the Purposes of such Processing
The Company will collect, use or disclose your Personal Data under legal basis and in accordance with the following purposes:

• For necessity for the performance of the contract to which you are the contractual party, or for the performance in accordance with your request prior to entering into the contract, including but not limited to:

○ Consideration of account registration requests;
○ Any other necessities for providing the best Services from the Company;
○ Providing support service, contact and request for information, accept request, receiving news or to inquire about the Services;
○ Enhancing and improving the Services’ quality, increasing the Services efficiency, and facilitating you in using the Service;
○ Processing data in order to render the Services; and
○ Any other processing related to the Services and possibly benefiting you.

• For compliance with the laws, including but not limited to:

○ To Comply with relevant laws in which the Company is subjected to, in compliance with laws, regulations, rules, codes of practice or guidelines issued by authorities or regulatory agencies, such as the Notification of the Bank of Thailand, Anti-Money Laundering Act and etc. In this regard, the Company may transfer your Personal Data to internal/external auditors, government agencies or other related juristic persons.

• Consent, including but not limited to:

○ Marketing purposes such as offering privileges and/or any products or services that may interest you, promotional campaigns, public relations, doing surveys in connection with the Services, including doing statistic, analysis, study and research, assessment of the information, or to manage the business needs of the Company, business partners or affiliated companies, through contact channels that you have provided such as e-mail; and
○ other legitimate purposes in which the Company has obtained consent from time to time such as to facilitate you in using the service of other service providers via the Application.

• For legitimate interests of the Company or any other companies other than the Company, except that such interests are overridden by the fundamental rights of your Personal Data, including but not limited:

○ Prevention of crime and fraud; and
○ Enabling security systems and networks to meet international standards.

• For substantial public interest which the Company has provided suitable measures to protect your fundamental rights and interest, including but not limited to:

○ Identification/verification of the identity in order to prevent crime and fraud; and
○ Suspicious of financial support for terrorism or money laundering.

Apart from the abovementioned legal basis and purposes, the Company may collect, use or disclose your personal under other legal basis, such as preventing or suppressing a danger to your life, body or health, or for the achievement of the purpose relating to the preparation of the historical documents or the archives for public interest. Where the collection, use or disclosure falls under other purposes in accordance with the mentioned basis, the Company will notify you afterward.

The Disclosure of Your Personal Data to Third Parties and the Collection of Personal Data from Other Sources.
For the processing pursuant to the purposes under abovementioned legal basis. The Company may collect from and/or use, send, transfer, process and/or disclose the Personal Data to the following persons:

• Juristic persons having control over the Company or under the control of the Company including other companies under the same control of the Company, or other juristic persons or persons in which the Company is a contractual party, or having the legal relationship with the Company, including other service providers having power in making decision to take any action related to your Personal Data both within and outside the country such as external service providers, cloud service providers or other business partners of the Company. In this regard, the Company shall ensure that those service providers will process your Personal Data in accordance with this Privacy Policy and the applicable laws;
• The auditors, external examiners of the Company, government authorities, transferee of the right of claim, and any other persons or juristic persons that the Company is required to transfer the Personal Data as necessary to comply with the laws; and
• Business/enterprise transferee in case the Company has merged, transfers, sells its assets and/or business whether entirely or partially.

Retention Period for Your Personal Data
It is necessary for the Company to retain your Personal Data for as long as necessary throughout the time you are still using the Services or having the relationship with the Company, or as long as necessary to achieve the purposes related to the Company’s Services. In this regard, the Company may continually retain such Personal Data in accordance with the laws such as the laws regarding Anti-Money Laundering, or for the purpose of verification and investigation in the event of dispute within the prescription as specified by law, for the period not exceeding 10 years.
However, the Company will delete or destroy your Personal Data, or make such Personal Data unidentifiable when it is no longer necessary to be retained or such retention period has ended.

Security
The Company acknowledges and realizes the importance of your Personal Data. Thus, the Company has improved and developed the security systems for your Personal Data in corresponding to the laws, and up-to-date with safety in accordance with the international standard at all time. The Company will proceed at its full effort to comply with this Privacy Policy, and will urge the Company’s personnel, including data processors, who are entitled to access the Personal Data or has legal duty, to keep and respect your Personal Data security.
In case the Company is necessary to transfer any of your Personal Data to foreign country, the Company will apply the standard as prescribed by the laws on personal data protection. Additionally, the Company will not transfer your Personal Data to the destination country that has no personal data protection standard sufficiently in accordance with the criteria as prescribed by the laws, except that you consent the Company to send or transfer your Personal Data to such destination country. However, in case of computer espionage resulting that your Personal Data has been stolen, whether by ways of hacking, stealing, copying or destroying database, destroying personal code (password mining) or any other methods, without the Company’s fault, in such circumstance, the Company will have the right to disclaim any liability resulting from such act.

Personal Data of Minors
The Company will collect, use or disclose the Personal Data of minors only in accordance with the standard as prescribed by the laws. In case the Company is aware of the import of minors’ Personal Data into the Company’s system, the Company shall take the appropriate action to rapidly manage such data.

Language
The translation of this Privacy Policy, whether in any language whatsoever, is for your convenience only, without any intention to change this Privacy Policy. In case of any discrepancy between Thai version and any other languages version, the Thai version shall prevail.

Contact
Should you have any question, complaint, request to access, or query regarding this Privacy Policy and/or would like to examine any of your Personal Data in possession of the Company. You may find your answers from frequently asked question (FAQ) or contact TrueMoney Customer Care throughout 24 hours via Live Chat on the Application or call 1240.

Improvement of Policy
Using any Services of the Company shall be deemed as the acceptance of this Privacy Policy. The Company may make amendment to this Privacy Policy at any time, and notify you of such amendment. Using the Application or any Services continually after the notification of such amendment will be deemed as acceptance of the amendment for each time.