1.4 The words "we", "us", "our" or any of their derivatives refer to StashAway Thailand and its successors and any novatee, assignee, transferee or purchaser of StashAway Thailand's rights and/or obligations hereunder and any reference to StashAway Thailand includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
2.2 The Personal Data that we collect or may collect include:
Section 2 sets out the type of Personal Data that we collect or may collect from you.
3.1 The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
3.2 As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any applicable law.
Section 3 sets out where we may obtain Personal Data from. As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data.
4.1 We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you on the following legal bases and for the following purposes("Purposes"):
4.2 You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer, at 725 Metropolis Building, 18th Floor Sukhumvit Road, Khlong Tan Neua, Wattana, Bangkok 10110, firstname.lastname@example.org or +662 821-6888.
4.3 We will use your Personal Data only where we have a lawful basis for using it. These lawful basis include where:
Section 4 sets out how we may use your Personal Data. This includes using your Personal Data for the provision of our Services / Platform to you, for marketing purposes, and to comply with regulatory requirements. We will use your Personal Data only where we have a lawful basis for using it, which include, pursuing our legitimate business interests; processing the information to perform our contract with you; processing the information to comply with a legal obligation; for the public interest, such as for the purpose of preventing or detecting crime; and having your consent.
We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Thailand or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:
We may also disclose and share your Personal Data with other persons in connection with the Purposes described in Section 4
To the extent necessary, we may transfer, store, process and/or deal with your Personal Data outside Thailand. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws. If the recipient countries do not maintain adequate standard levels, we will ensure that the transfers are in compliance with legal requirements and will put in place the as necessary and appropriate measures for the purpose of protecting your Personal Data.
We may transfer your Personal Data outside Thailand. If we do, we will comply with applicable data protection and privacy laws.
Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other business purposes or to comply with any Applicable Laws and in accordance with our policy or manual on data retention of StashAway Thailand.
We may retain your Personal Data for as long as it is necessary for the purpose it was collected, for business purposes or to comply with applicable laws.
However, you may also
You may contact our Data Protection Officer to access or request changes to your Personal Data
9.2 Please note that we may not be able to provide you with our Services if you do not agree to our collection, use, processing and disclosure of the Personal Data for any of the Purposes.
10.2 A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
10.3 You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites or the Platform.
10.4 We also use analytics programs such as Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Features of Google Analytics that we may use include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Accordingly, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience. You may refer to https://www.google.com/policies/privacy/partners for more information about how your data is collected through Google Analytics.
10.5 We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads.
10.6 Using the Google Ad Settings (https://www.google.com/settings/u/0/ads/authenticated), you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.
If you have any questions about any aspects of this policy or your Personal Data, please contact our Data Protection Officer, at 725 Metropolis Building, 18th Floor Sukhumvit Road, Khlong Tan Neua, Wattana, Bangkok 10110, email@example.com or +662 821-6888.
StashAway Asset Management (Thailand) Co., Ltd (Registration no: 0105562135522) has a Securities Business License Type C - Private Fund Management (Lor Khor-0136-01) from the Ministry of Finance and is regulated by the Securities and Exchange Commission, Thailand.