Privacy Policy
BluePay 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 BluePay application (the “Application”), payment 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, including but not limited to any services relating to the usage of applications, websites and other channels provided by 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. Otherwise, please immediately stop using the Service.
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, signature;
Necessary contact information such as contactable address, telephone number;
Particular personal characteristics such as status, biometrics data, photo;
Education and/or career information;
Financial information such as records of transactions made through BluePay accounts or other Services, credit card information, deposit account information;
Information relating to your devices, system, and usage behaviors, including but not limited to device identity number in relation to network connection (such as IP address, MAC address, Device ID), Advertisement ID, mobile device operating systems, mobile network service provider, location, device usage details, cookies, phonebook, application usage, technical information, model and type of devices, photo, image and photo album;
Camera Permission to ensure you can use services such as taking ID photos;
Upload Photo Permission to access your photo storage so that you can select photos for use, such as when uploading identification documents;
Storage Permission to access your device's storage to ensure you can save photos after they are created or edited;
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:
- 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;
- Any purposes in relation to the provision of Services that possibly be the interest or benefit to you via the notification on Application or contact channel that you have provided to the Company, and that the Company has legitimate rights regarding the provision of Services; and
- Any other processing related to the Services and possibly benefiting you.
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.
For the purpose of analysis or forecast your preferences or behaviors including conducting research, development, products improvement and marketing strategy to provide you with products and services, privileges, promotional campaigns or proposals, that are analyzed and selected, to you;
For the purpose of obtain camera permissions, and enable you to take ID photos, shoot your face video, and/or click and upload photos of your documents and other necessary documents during the KYC process. You can disable this permission anytime through the app or your phone’s settings;
For the purpose of access specific photos you choose to upload through your device's file picker and just use them to the purpose directly relating to our business and/or product. We only access the exact photos you manually select and never scan your full photo library. If we tend to use your photos for other purposes in future, we will request your consent once again. In addition, we guarantee that we will never share your photos with any third party unless your consent or required by law. To delete uploaded photos, you can contact us through the contact details provided by us;
For the purpose of access your device's storage to ensure you can save photos after they are created or edited;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.
Prevention of crime and fraud;
Enabling security systems and networks to meet international standards; and
Fraud prevention and security management of your BluePay account.
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;
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
The Company will retain your Personal Data for a period necessary to fulfill the purposes of providing services, or for as long as necessary in connection with the purposes set out in the contract or legal relation to be enforced between you and the Company. Unless it is required by applicable laws or regulations enforcing to the Company, to comply with internal practices of the Company, to comply with legal claims, or as requested by regulatory authorities, the Personal Data may be further retained for a period as reasonable and as necessary for each category of Personal Data.
The Company will erase or destroy or anonymize Personal Data to be an unidentifiable data by following the Company’s data destruction standards, when it exceeds the retention period or when the Company has no right or no other legal basis allows the Company to process your Personal Data.
Your legal rights under the Personal Data Protection Act B.E. 2562 (the “PDPA”)
As the data subject under the PDPA, you have the legal rights as the following:
1. Right to withdraw your consent
You have the right to withdraw your consent which you have provided to the Company for the processing of the Personal Data during the time of such Personal Data possessed by the Company.
2. Right to access to and obtain a copy of the Personal Data
You have the right to request access to the Personal Data which you have provided to the Company or to obtain a copy of such Personal Data in the format which is readable or commonly used by the ways of automatic tools or equipment, or can be used or disclosed by automated means (if provided by the Company), or request the Company to send or transfer such Personal Data to other data controllers (unless it is impossible to do so because of the technical circumstances), including to request the disclosure of the acquisition of the Personal Data obtained without your consent.
3. Right to rectify the Personal Data
You have the right to request the Company to rectify any inaccurate Personal Data which you have provided to the Company, or to complete any data during the time of such Personal Data possessed by the Company.
4. Right to erase or destroy the Personal Data or anonymize the Personal Data to become the anonymous data which cannot identify the data subject
You have the right to request the Company to erase, or destroy, or anonymize the Personal Data which you have provided to the Company to become the anonymous data which cannot identify the data subject for some reasons.
5. Right to restrict the use of Personal Data
You have the right to request the Company to restrict the use of the Personal Data which you have provided to the Company for some reasons prescribed by laws.
6. Right to object the processing of Personal Data
You have the right to object the Company for the processing of the Personal data which you have provided to the Company for some reasons prescribed by laws.
7. Right to file complaint for the violation of the PDPA by the Company
You have the right to file complaint to the Personal Data Protection Committee if the Company, including its employees or contractors have violated or not complied with the PDPA.
In this regard, you may send your request to the Company’s Data Protection Office for exercising your abovementioned rights via email. The Company will proceed in accordance with your request at its full effort within the reasonable time required by the PDPA. In addition, the Company will notify you the possible effect from processing of such request. However, the Company is entitled to deny any of your request if there is any specific legal ground allowing the Company to do so. Moreover, the Company reserves the right to charge for any expense from serving your request based on administrative cost and the Company’s internal policy.
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 person without fully legal competence
If you are considered as a person without fully legal competence, which includes a minor (age below 20 years old or not sui juris), an adjudged quasi-incompetent or incompetent person by the court, in case of necessity to collect, use or disclose your Personal Data, the Company shall conduct only in accordance with the procedures and standard as prescribed by the laws.
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.
Contact
Should you have any question, complaint, request to access, or query regarding this Privacy Policy and/or would like to examine any of provided Personal Data in possession of the Company. You can contact the Company as detail below:
BluePay Company Limited
Address : BluePay Company Limited, 319 Chamchuri Square, 24th Floor, Room No.24072, Phaya Thai Road, Pathum Wan Sup-district, Pathum Wan District, Bangkok 10330