AIA INVESTMENT MANAGEMENT (THAILAND) LIMITED – PERSONAL INFORMATION COLLECTION STATEMENT
Last Update as of 8 July 2021
AIA Investment Management (Thailand) Limited ("AIAIMT", "we", "us", "our"), an indirect owned subsidiary of AIA Group Limited and a part of AIA Group Limited group of companies ("AIA Group"), and its affiliates ("AIA", "we", "us", "our") recognise our responsibilities in relation to the collection, use, disclosure and other processing and storage of personal data.
This personal information collection statement ("privacy statement") provides you with notice as to how your personal data is collected, what personal data is collected, for what purposes your personal data is collected, used, disclosed or transferred, to whom your personal data may be disclosed or transferred, and how to access, amend and otherwise exercise your rights in respect of your personal data. You are required to read and understand this statement, before giving your consent for us to collect, use, disclose and otherwise process of your personal data. If you are less than 20 years old, your parental or guardian consent is additionally required.
HOW WE COLLECT PERSONAL DATA
We may collect and retain your personal data in the following -situations:
when you open the account for our funds transactions, including our services whereby your data shown in account opening documents, account opening applications, services applications, and documents required for opening an account , or when you access or use our or third parties’ websites, apps, and online, mobile, telephone or other services (“Products” or “Services”);
when you submit documents and order forms for subscription, redemption, switching, or in consideration of the subscription, redemption, transferring, switching, or other transactions of our units trust, Products or Services;
when you submit requests for changes or updates to your Products or any other requests in connection with your Products including through the submission of Product servicing forms and relevant documents;
when you respond to our queries or when you request for us to contact you;
when you interact with personnel, investment advisors, customer service officers, sales representatives, agents, brokers, intermediaries, contractors, business partners, counterparties, service providers or other associated persons or organisations of AIAIMT or AIA Group and any distributors of these persons or organisations (collectively “AIAIMT Persons and Partners”), via websites, apps, social media, phone, email, face to face meetings, interviews, SMS, fax, regular mail or otherwise;
when we receive referrals or collect personal data from AIAIMT Persons and Partners;
when you submit personal data to us to participate in lucky draws, contests, events or competitions organised by or on behalf of AIAIMT or AIAIMT Persons and Partners; or
when we seek information from third parties about you, including but not limited to information from investigators, publicly available sources, private or commercial information sources, websites, application, social media sources, data providers, Association of Investment Management Companies , in connection with your product, product applications, product claims and/or Products and Services of AIAIMT used or purchased by you (“Third Party Sources”);
when we seek information from third parties about you for compliance and other regulatory purposes.
By providing us with any personal data relating to a third party (including but not limited to family members or beneficiaries), you represent and warrant the accuracy of such personal data and that you have fully informed our collection, use, disclosure and transfer of such third party’s personal data for the relevant purposes, and have obtained such third party’s prior consent before collection of the personal data relating to a third party, except to the extent that such consent is not required under applicable laws and regulations.
To the fullest extent permitted by law, you further agree to keep us fully indemnified from and against any and all damages, losses, costs, legal fees, penalties and litigation expenses, including any fine or other amounts levied, imposed or charges by any regulator or regulatory authority, arising out of or in connection with your (or those of your officers, employees, advisors, agents or representatives) acts or omission, fault or negligence in performing these obligations or which result in us breaching any applicable laws.
WHAT PERSONAL DATA DO WE COLLECT, USE OR DISCLOSE
The personal data we collect, use and disclose (which includes sensitive personal data as provided in the Personal Data Protection Act B.E. 2562, as amended from time to time, and other relevant applicable laws and regulations), includes the following:
your personal data which enables your identification in your account opening documents, account opening applications, services applications, and documents required for opening an account, such as your name, surname, identification numbers, passport numbers, phone numbers, email addresses, postal addresses and other contact details, date of birth, occupation, photographs, marital status, political status and information about your dependants, Biometric data, Health data, and video/photo and voice recordings in case you contact with us through our contact or communication channels and etc. and whether you provide us such data or such data is with us or we obtain from or access to reliable sources such as government agencies, AIA group, and/or our partners/alliances or our advisors;
your financial information or transactions information with AIAIMT such as income, source of income, expense, tax information, bank account numbers, bank statements, investment information such as unitholder numbers, investment units transaction numbers, credit card numbers, debit card numbers, deposit amount, investment information history and records with AIAIMT, and other payment details;
your employment information and employment history;
information relating to your civil or criminal history records, such as criminal history, civil and other litigation records;
details of the products and services you have purchased with AIAIMT or other companies, beneficiary, payer name, Anti-Money Laundering and Anti-Terrorist Financing of Thailand and other related countries and bankruptcy statuses, Foreign Account Tax Compliance Act (FATCA), police reports and court orders;
technical information and personal activities/preferences collected when you use certain websites, apps and social media platforms, such as customer’s unique identification on social media platforms, IP address, browser type and version, time zone settings, browser plugin types, operating systems and platform, user profile, device information (including with respect to mobile devices the IMEI number, wireless networks and general network information), websites searching for our products and websites browsing from cookies or linking to other websites where you search information; and
personal data of a third party that you provide to us in connection with the purchase or use of our Products and Services, or for referrals.
The provision of your personal data is voluntary. You may choose not to provide us with the requested data, but failure to do so may inhibit our ability to do business with you or to respond to your enquiries.
PURPOSES FOR WHICH PERSONAL DATA IS COLLECTED, USED OR DISCLOSED
Personal data is collected or may be used, disclosed or transferred for the following purposes:
to offer, sell, provide, manage, operate, process and administer our Products and Services to you;
to process, administer, implement and effect the requests or transactions contemplated in this document or any other documents you may submit to us from time to time, including without limitation to evaluate your financial needs and provide recommendations of suitable products and services to you; to process account opening applications for investment; to verify your identity and to perform customer due diligence; to administer your Products; to investigate, analyse, process and procedure relating to subscription order forms, redemption order forms, switching order forms, transferring order forms for investment units; and to pay for subscription, switching, transferring for investment units; and to edit or modify funds and your request to edit your information;
to exercise any right under your investment including right to accept the transfer of investment units, if applicable;
to design new or enhance existing Products and Services of AIAIMT;
to communicate with you, send and/or receive your documents with us, including to communications of administrative and other communications about any Product or account you may have with us, to provide technical support for our websites and apps, or about future changes to this privacy statement;
for market research, advanced data analytics, reporting or financial assessment undertaken by AIAMT, the AIA Group, AIAIMT Persons and Partners, or our respective regulators;
for investigation or prevention of fraud-related activities and other actual or suspectedviolations, particularly to communicate with companies within the financial services including for sharing personal data to raise the standard of work for companies in the same industry to prevent, handle, reduce abovementioned risks, and to communicate with our respective regulators;
for purposes of corporate reorganisations and corporate transactions
to provide you with access to the content on certain websites, apps or social media platforms;
to monitor your behaviour, such as your use of certain websites, apps and social media platforms, conduct analysis of your use of them and understand your preferences in order to personalise, operate, evaluate and improve them, or our Products and our Services, troubleshoot any problems, provide recommendations of relevant Products and Services and provide targeted advertising on our websites, apps or other channels;
for regulatory compliance, risk management and (internal and external) audit reviews of AIAIMT’s business;
to meet requirements of prevailing internal policies of AIAIMT or AIA Group including transferring information to AIA Group for meeting such requirements under the Binding Corporate Rules of the AIA Group Data Privacy Policy which may disclose your or customers’ personal data to Third parties (Outsource) for keeping and maintaining such personal data in the Cloud Computing System and for purposes of development of our Information Technology ;
to examine email or internet uses for incoming and outgoing communications between our employees and customers to protect the confidential information of AIAIMT to Third parties.
for purposes of storage, archiving, back-up or destruction of personal data;
to comply with applicable laws, rules, regulations, agreements or measures imposed by any government regulators, law enforcement agencies, government authorities, dispute resolution agencies or asset management industry governing bodies ,regardless of any entity such as preventing and detecting irregular transactions that lead to illegal activities or suspicious transactions, being compliance with Financial Institution Business Laws, Securities and Exchange Laws, Life Insurance Laws, Non-life Insurance Laws, Tax Laws, Anti-Money Laundering Laws, Counter-Terrorism Financing and Proliferation of Weapons of Mass Destruction Financing Laws, Computer Laws, Bankruptcy Laws and other Laws that we are subject to ,both Thai and Foreign law including and its sub-regulations and notifications.
to assist in law enforcement purposes, investigations by us or on our behalf, by police or by other government or regulatory authorities in any jurisdiction, and to meet reporting obligations and requirements imposed by laws or agreed to with government or regulatory authorities in any jurisdiction;
to capture and record images of people who come to AIAIMT office and areas by using CCTV system, including card exchange before entering the building for security within our office areas;
to maintain relationships with customers such as handling complaints, offering special privilege without marketing objectives to customers and etc;
for quality and training purposes when our communications are recorded;
to conduct general administration in connection with the foregoing purposes; and
to perform other necessary activities directly relating to any of the above purposes.
Unless otherwise permitted by applicable laws and regulations, we will obtain consent from you if we wish to use your personal data for purposes other than those stated in this privacy statement or or other than directly related purposes in this privacy statement.
For our Product on using your personal data for promotional or marketing purposes, please see the section entitled “Use of Personal Data for Direct Marketing Purposes” below.
WHO MAY BE PROVIDED WITH YOUR PERSONAL DATA
Personal data will be kept confidential but we may, where permitted by applicable laws or where such disclosure is necessary to satisfy the purposes or directly related purposes for which the personal data was collected, provide such personal data to the following parties:
any person authorised to act as an AIAIMT Person and Partner for the sale, distribution or servicing of Products and Services offered by AIAIMT or an AIA Group company to you;
any person who is employed or contracted to work for such AIAIMT Person and Partner for the sale, distribution or servicing of Products and Services offered by AIAIMT or an AIA Group company to you;
any person authorised to act as an AIAIMT Person and Partner to help deliver our Products or Services offered/sold to you, such as securities companies, insurance companies, reinsurance companies,Securities Brokerage Company, Limited broker, dealer and underwriter distributors (LBDUs), investment or asset management companies, ratings agencies, investigation companies or other partners;
any AIAIMT Persons and Partners who provide any administration services, including but not limited to data processing services, business processing services, financial services, accounting services, payment services, debt collection or securities clearing services, telecommunication services, technology services, cloud services, outsourcing services, call centre services, storage services, document processing, archiving services, scanning services, mailing services, printing services, courier or messenger services, data analytics services, marketing services, research services, crisis management services or other services in connection with the operation of AIAIMT's business or the provision management, operation, processing or administration of our Products or Services to you;
disclosure beneficial owner information to securities companies/investment or asset management companies in foreign countries, upon the citation of foreign law as the governing law. foreign laws;
Your co-owner or joint owner who have the access to the same account(a). ;
association of investment management companies;
association of securities companies or any related clubs;
any law enforcement agencies, statutory boards, government or regulatory bodies, dispute resolution bodies, or any other person in any jurisdiction to whom AIAIMT or another member of the AIA Group must disclose data such as the Securities and Exchange Commission (Thailand), Anti-Money Laundering office, Revenue department, Legal Execution department, Office of Insurance Commission, The Royal Thai Police and any persons as required by applicable laws or regulations, etc : (a) under a legal and/or regulatory obligation in Thailand or in that jurisdiction or in any other jurisdiction applicable to that particular AIA Group company; or (b) pursuant to an agreement or scheme between the AIA Group company and the relevant governments, regulatory bodies or other persons;
any members of the AIA Group;
our professional advisors such as lawyers, auditors or consultants;
any persons or parties to whom you have consented the disclosure of your personal data;
any other persons or parties permitted under applicable law;
Other Third Party Sources
CORPORATE TRANSACTIONS
From time to time, AIAIMT may acquire or dispose all or substantially all its assets to another entity and for this purpose, to the extent permitted by applicable laws, your personal data may be transferred or disclosed as a part of such acquisition or disposal or offer to acquire or dispose ..
In the event of acquisition, the personal data received with that business would be treated in accordance with this privacy statement, if it is practicable and permissible to do so. In the event of disposal , merger and acquisition contracts should contain provisions requiring the purchaser to treat your personal data in the same manner required by this privacy statement.
THIRD COUNTRY/CROSS-BORDER TRANSFER
Your personal data may be transferred to, stored or otherwise processed by AIAIMT, or provided to any of the above persons who may be located or who may provide services, in or outside Thailand. Where required under relevant law, we may seek your consent to the transfer of such information outside Thailand to our facilities or to those third parties with whom we share it as described above. Your personal data will only be transferred to other locations, where we are satisfied that adequate levels of protection exist to protect the integrity and security of your personal data, which as minimum are comparable to the jurisdiction or territory in which you provided such personal data.
SECURITY AND RETENTION OF PERSONAL DATA
AIAIMT applies reasonable security measures to prevent unauthorised or accidental access, processing, erasure, loss or use.
AIAIMT may retain your personal data for as long as necessary to fulfil the purpose(s) for which it is collected or a longer period as otherwise required to ensure compliance with applicable laws and regulations.
Reasonable steps will be taken to delete or destroy your personal data when it is no longer necessary for any of the purpose above.
YOUR RIGHTS WITH RESPECT TO PERSONAL DATA AND POINT OF CONTACT
You have the right to:
verify whether AIAIMT holds any personal data about you, to access or obtain a copy of any such data, and/or to access information about how AIAIMT uses or discloses your personal data;
require AIAIMT to correct any personal data relating to you which is inaccurate;
request that the processing of your personal data be restricted under certain circumstances;
request deletion or destruction of your personal data under certain circumstances;
request a temporarily suspension of the processing of your personal data under certain circumstances;
request transferring your personal data by obtaining your personal data from us if we organize such personal data in automatic machine-readable or usable format and can be processed or disclosed by automatic means including (a) to request us to send or transfer the personal data in such format directly to other data controllers if doable by automatic means; or (b) to request to obtain the personal data in such format sent or transferred by us directly to other data controller unless not technically feasible;
withdraw your consent or request a change to your scope of consent;
request deregistration or deletion of your registered account (if any);
make a complaint about AIAIMT's data handling; and
enquire about AIAIMT’s policies and practices in relation to personal data.
Requests for access, correction, complaints or other queries relating to your personal data should be addressed to:
Under applicable laws and regulations, we may have the right to charge reasonable costs for the processing of the above personal data requests.
If you suspect any breach involving personal data, please notify Data Protection Officer (DPO) via email at aiaimt.privacy@aia.com or contact at the following address:
You may withdraw your consent to collect, use, maintain or disclose (part of) your personal data as set out in this privacy statement by giving us reasonable notice.
If you withdraw your consent for us to collect, use, maintain or disclose your personal data for non-marketing reasons, we may be unable to process, administer and/or manage your Products, relationships and/or accounts with us. In such event, you may be required to redeem all your investment units or terminate all your accounts or withdraw from all any accounts or any programmes in which you are participating. This may be to your disadvantage, as you may be losing valuable benefits from your accounts or programmes, incur any accounts termination charges or it may not be possible for you to obtain a similar level of protection on the same terms in the future.
AMENDMENTS TO THIS PRIVACY STATEMENT
AIAIMT reserves the right, at any time and without notice, to add to, change, update or modify this privacy statement, to the extent permitted by laws, simply by notifying you of such change, update or modification. The notification could be made by email or other common mode of communications.
Where required by applicable laws, we may also notify you in the event of material changes to this privacy statement and, where required, seek your consent to those changes.
ADDITIONAL INFORMATION
Should you have any questions on any part of this privacy statement or would like additional information regarding AIAIMT's data privacy practices, please do not hesitate to contact us (see the section entitled “Your rights with respect to Personal Data and Point of Contact” above).
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USE OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES
To provide you with information about our products and services, AIA Investment Management (Thailand) Limited ("AIAIMT", "we", "us", "our") would like to use your name, surname, age, gender, email address, telephone (including mobile) number, and postal address you provide to us ("contact details") to,
send you promotional materials and direct marketing communications about our products, services, advice and provide information in any subjects, including funds prospectus; funds fact sheet; products publicity; sales promotion organizing; funds news; investment information and new; data analysis; training; seminar organizing; reward/loyalty/privilege programmes; charitable/non-profitable causes ("Classes of Marketing Subjects"); and
to administer contests, lucky draws, events and competitions to which you choose to participate.
We are required by law to obtain your explicit consent in order to do so.
We would also like to share your name and contact details with AIAIMT Persons and Partners providing any of the Classes of Marketing Subjects and call centre, marketing or research services so that they can send you promotional materials and conduct direct marketing in relation to the products and services they offer, but we also cannot do so without your written consent.
If you do not want to receive any direct marketing communications, you may withdraw your consent at any time free of charge by contacting in person at:
AIA Investment Management (Thailand) Limited
181/19 AIA Tower 2 Fl.11th , Surawongse Road, Suriyawongse Subdistrict, Bangrak, Bangkok 10500 or inquire for more information at tel. no. 02-353-8822 or email at aiaimt.customer@aia.com.
