Privacy Policy

Pantavanij Company Limited (the “Company”) realize the importance of the privacy and the personal data protection for the Company’s clients, customers, visitors of the website, applications or any system operated by the Company (collectively called as “you”). Thus, the Company has established the privacy policy in order to notify you about the Company’s process of collecting, using and disclosing the personal data, as well as, the rights for your personal data protection as prescribed by the applicable laws on personal data protection. This will enable you to confidently use website, applications or any system operated by the Company, including any and all services of the Company (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, voice recording data;
  • Career information such as position;
  • Financial information such as records of sales transactions made through the Services, 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;

Account login information and any information recorded from your access to the Services such as login ID, password, and/or security question and answer, profile picture, log file.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. 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 website, application or any system operated by the Company .
  • For legitimate interests of the Company or any other person 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 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, 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.

Your Rights

You have the rights as follows:

  • To request for accessing your own personal data held by the Company, and to request for obtaining the copy of personal data related to you, or to request for the disclosure regarding the acquisition of personal data that you did not give the consent;
  • To request for obtaining your own personal data in normal readable or usable form by the device or equipment automatically operating, or for using or disclosing such personal data by automatic method (in case of preparing by the Company), or to request the Company to send or transfer such personal data to any other personal data controller as prescribed by the laws, and including to request for obtaining your own personal data that the Company has sent or transferred to any other personal data controller, (except that it cannot technically be done);
  • To oppose the collection, usage or disclosure of your personal data as prescribed by the laws;
  • To request the Company to delete, destroy, temporarily suspend the usage, or convert the personal data into the form of non-personally identifiable information;
  • To request the Company to suspend the usage of your personal data;
  • To request the Company to amend or add the personal data to be accurate, up-to-date, complete, and not causing any misunderstandings;

In this regard, the Company will have the right to amend any inaccurate personal data that you used or presented to the Company for obtaining the Services, after the Company has received the accurate personal data together with the supporting evidence. This will be at the Company’s discretion;

  • In case you wish to cancel the Services, then, you can revoke the consent given to the Company in accordance with the method as specified by the Company. Such revocation of consent will not affect the collection, usage or disclosure of the personal data that you have already given the consent;
  • To file the complaint with the authorities, for the case that the Company does not comply with the Privacy Policy.

However, you acknowledge that such rights are the basic rights. You may exercise such rights in accordance with the provisions of the applicable laws. Additionally, the Company, being as the said personal data controller, is entitled to reject your exercising of such rights.

If you exercise any of your rights under data protection law, the Company shall respond promptly and shall put our best effort to process such request, free of charge, within one calendar month after receiving all required supporting documents. Please be aware that the Company might charge a reasonable fee for complex, unfounded, excessive or repetitive request.