“Personal Information”

The same definition as “personal data” is defined in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which refers to any data belonging to a person that permits that person’s identity, whether directly or indirectly, but expressly omits data of the deceased.

“Sensitive Personal Information”

The same meaning as “sensitive personal data” prescribed in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which refers to personal data relating to a person’s race, ethnicity, political opinion, cult, religious or philosophical beliefs, sexual behavior, criminal records, health, disability, labor union, genetics, biometrics, or any data which may affect the data subject in the same way as prescribed by the Regulator.

“Use”, “Process”

The same meaning as “processing” as defined in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which includes, among other things, collecting, processing, retaining, disclosing, and so on.

General

Maikeru Asset Management Company Limited is dedicated to safeguarding any personal information provided to us. Privacy is important to us, and we will only collect and use personally identifiable information if it is both necessary and lawful.

Maikeru Asset Management Company Limited has prepared this Privacy Notice to inform you about the types of personal information we collect; what we do with that information; who we may share it with and why; and your choices and rights regarding your personal information.

We may need to amend our Privacy Notice from time to time, so please monitor our website for updates. If we make significant changes to how we handle your personal information, we may contact you to notify you.

Maikeru Asset Management Company Limited is a global asset management company. We invest and manage assets for institutional investors and private clients, and we provide investment strategies and solutions to our clients.

Personal information we collect and use

We may collect and use personal information, including:

• For identification and security purposes, information about who you are, such as your Full Name, Date of Birth, Gender, Marital Status, Country of Birth, National Identification Card Number, Nationality, Passport Number, Expiry Date and Place of Issuance, Occupation and employment details, including job title, salary, and employer’s address;
• Information that will allow us to contact you, such as your address (current address in Thailand and Registered home address if different), Phone number (mobile), and email address;
• Information connected with your product or service with us, e.g., bank account and sort code
• Information about your contact with us, e.g., phone calls, emails, or letters;
• Information that is automatically connected, e.g., via cookies, when you visit one of our websites;
• The information is described as “sensitive personal information,” i.e., information pertaining to your race, ethnic origin, political opinions, cult, religious, or philosophical beliefs, sexual behavior, criminal records, health, disability, trade union information, genetic data, biometric data, or any other data which may affect you in the same manner, as prescribed in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”). Such sensitive personal information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information;
• Information on persons connected to you, where required to provide the agreed product or service, e.g., name, date of birth, nationality, National ID number, or Passport Number of your spouse or beneficial owner.

If you have a distributor, broker, or agent, the information we gather and utilize was most likely submitted on your behalf by them.

Why do we collect and use your personal information

We value your privacy and will only collect and use your information when it is both necessary and legal. We will only collect and use your information if we can meet one of the data protection laws’ legitimate processing criteria. These include:

• Where necessary to offer the product or service you have requested, for example, if you want to invest in one of our funds or products, we will need certain personal information from you, such as your name, address, date of birth, and bank account information;
• Where information is essential for us to satisfy our legal or regulatory requirements, such as sending you Annual Statements, informing you of changes to our Terms and Conditions, or detecting and preventing fraud,
• For our legitimate interests when they do not outweigh yours as the data subject, such as developing new goods and services for our customers;
• For the completion of duty that we are required to complete in the public interest;
• You have given us express permission to use your personal information for the agreed-upon purpose. For example, if we are moving your personal information outside of Thailand for processing purposes, if we are collecting and utilizing sensitive personal information, if we are doing certain sorts of marketing and research, and/or if we are handling calls, you can opt out of such activities by contacting us using the details provided below.

Subject to the restrictions set out above, we may use your personal information for the following purposes:

• Account opening, including information verification and credit checks
• Order Handling
• Unit Allocation
• Regulatory and Compliance Reporting
• Service Request (Amendment, Online Trading, Withdrawal, Redemption, Closure, and Tax Certificate)
• Payment Application
• Dividends Confirmation
• Marketing and Research, including analysis and promotion, with your explicit consent
• Call Handling (incoming and outgoing)—with your explicit consent.

As indicated above, you will be asked to give the personal information necessary to be processed by or on our behalf. If you do not agree to disclose such personal information to us by this Notice, we may be unable to supply you with the requested product(s) or service(s) or meet any of our contractual responsibilities to customers.

Proper Management and Protection of Personal Information 

We take personal information and security extremely seriously, and we endeavor to always meet our duties. Any personal information collected and used by us in any way will be subject to adequate safeguards to ensure the management and protection of your personal information. We have put in place the following measures:

• We have established an organizational culture that promotes and ensures the security of any personal information that we hold.
• Personal information controllers have been appointed to supervise the appropriate management of your personal information.
• To guarantee the correct treatment of personal information, internal firm policies based on Personal Information Protection Laws and instructions published by the competent government were formed;
• We have educated our workers to guarantee that they appreciate the importance of personal information security and are well-versed in all relevant regulations and guidelines;
• Developed a personal information management registry and enforced appropriate access controls to personal information;
• Established suitable and reasonable security measures [such as a secure storage mechanism with restricted access restrictions] to prevent unauthorized access to, or leakage, destruction, or modification of, personal information. Our security measures are based on industry standards and best practices, and they provide an acceptable control environment for managing threats to the confidentiality, integrity, and availability of your personal information.

Disclosure of Personal Information to Third Parties  

We may share your personal information with third parties with whom we collaborate for the objectives stated in the section under “Why we gather and use your information.”

We will only release your Personal Information to such third parties if it is legal and in accordance with our duties under data protection legislation.

We will share your information with the following parties:

• Other components [subsidiaries, holding companies, linked organizations, or future affiliates of ours] who assist us in providing the product or service you have
• Companies and partners, both inside and outside of Thailand, that we have carefully selected to help us;
• Credit reference companies are used to conduct credit checks and ID verification.
• Where this is necessary as part of the product or service you have agreed upon with us, your distributor, broker, or agent,
• Our Thai regulators include the Securities and Exchange Commission (SEC) in Thailand.
• Appointed agency [government agencies, public agencies, agencies] in charge of monitoring service delivery;
• Law enforcement agencies, for example, for crime prevention and detection, as well as the pursuit of legal actions; and
• Other third parties may be necessary to assist in the reorganization, amalgamation, merger, or sale of an organization.

By sharing your personal information with such third parties, we assure you that those individuals will keep your information secret and will not use it for reasons other than those mentioned by us.

We will only authorize a third party to process your personal information on our behalf after obtaining the appropriate assurance that they will manage and secure your information in accordance with relevant laws. Furthermore, before we provide and disclose your personal information to such service providers, we require assurance that they will process this data strictly by our instructions and agreed-upon terms of use, including appropriate measures to properly handle personal information, via a written contract or similar means. We audit their continued compliance with these requirements on a regular basis.

How long we keep your information

We maintain your personal information and copies of records we make (e.g., conversations with us) while you are a client or customer of ours to offer your product or investment and satisfy our legal and regulatory requirements.

Even if you no longer have a connection with us, we must retain information for a variety of legal and regulatory reasons. The amount of time will vary, and we will assess our retention periods on a regular basis to ensure that they comply with all laws and regulations.

Personal data must be destroyed or anonymized at the end of the appropriate retention term. If data cannot be assigned to an identifiable individual at the end of the retention term, no action is necessary in some situations.

Your rights under the law

Under data protection legislation, you have several rights that you can use in specific circumstances.

These are:

1. Right to be Informed
2. Right to Withdraw Consent
3. Right of Access
4. Right to Receive and Transfer
5. Right to Object
6. Right to Erasure and Destroy
   – Your personal information is no longer required for the reasons for which it was collected, utilized, or disseminated.
   – You revoke the permission that is the basis for the collection, use, or disclosure, and there is no legal basis for such collection; and
   – You are opposed to the collection, use, or disclosure of Personal Data as defined in Section 32 of the Personal Data Protection Act.
7. Right to Restrict

If you want to exercise any of your legal rights, please contact us and ask for the Data Subject Rights Request form. Instead, you can tell us about any changes using the information provided below.

How to contact us 

Please contact us if you have any questions regarding our Privacy Notice or the information we collect or use about you:

Thailand’s Data Protection Officer
Maikeru Asset Management Company Limited
Level 18, Park Ventures Ecoplex, 57 Witthayu Rd., Lumphini, Pathum Wan District, Bangkok 10330, Thailand
Email: contact@maikeru-assetmanagement.com

How to make a complaint 

Your personal information will always be collected, used, and safeguarded by data protection laws. If you feel we have not treated your information in accordance with this Privacy Notice, please notify us immediately, and we will do everything possible to put things right.

While we try to address any issues for you, you have the option of contacting your local data protection authorities, such as the SEC in Thailand. Whether you have exhausted our complaint system, you still have access to it.

You can contact the Office of the Personal Data Protection Committee at the following address:

Office of the Personal Data Protection Committee, Office of the Permanent Secretary
Ministry of Digital Economy and Society
5th December, B.E. 2550
120 Moo 3, Bldg. B, 6-9 Floor
Chaengwattana Road
Laksi, Bangkok 10210

E-mail: pdpc@mdes.go.th
Tel: +66 2 142 1033