Kasikorn Asset Management Co., Ltd. (“KAsset") operates its business in adherence with ethical standards and respect for your privacy. KAsset places importance on personal data protection and security to ensure that your Personal Data obtained by KAsset will be used in accordance with the specified purposes and in compliance with applicable laws. KAsset has formulated this personal data protection policy (this “Policy") to inform you, as a data subject, of the objectives and details for the collection, use and/or disclosure of Personal Data, including your legal rights.

1. To whom will this Policy apply, and what are channels for personal data collection?

    1.1. To whom will this Policy apply?

This Policy shall apply to you if you are classified as one or several types of the following persons.

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1.2. Channel for collection of personal data

KAsset may collect your personal data via the following channels:

(1) Personal Data that you provide directly to KAsset, or through selling agents, private fund marketing representatives, or other intermediaries that you use to contact KAsset for transactions, or Personal Data already held by KAsset  as a result of your use of products and/or services, contact with KAsset, visits, participation in activities, searches through service channels and/or various communication channels of KAsset, such as the head office, website, application, KAsset's social media accounts, email, telephone, facsimile, postal mail, short message service (SMS), questionnaires, business cards, meetings, training sessions, seminars, events, recreational activities, marketing promotion activities, personal interactions, or any other channels.

(2) The personal data received or accessed by KAsset from other sources, such as government agencies, other companies within KBank Financial Conglomerate or financial institutions, financial service providers and other service providers of KAsset, business partners and service providers of business partners, companies that jointly issue products and/or services with KAsset, the information service providers, KAsset's customers, individuals or juristic persons conducting a transaction with KAsset (as you having involvement with such transactions as mentioned above), registrar, securities issuer, Thailand Securities Depository Co., Ltd. (TSD), online social media, online platform of third party, public data sources (such as Government Gazette), a person having legal authority or legal right, any other person or agency with which KAsset has a legal relationship, etc.

2. Which personal data does KAsset collect, use, and/or disclose?

    2.1. Personal data is the data that can directly or indirectly identify you, i.e.

           2.1.1. Individual means Individual Customer, individual having involvement with transactions of KAsset or KAsset's customers and general individual.

        2.1.2. Personnel of Juristic Person means individual having involvement with a juristic person which is a customer of, or conducts transactions with, KAsset.

2.2 Sensitive Personal Data

“Sensitive Personal Data" means personal data which is specifically determined by law. KAsset has no intention to collect Sensitive Personal Data from you.

In certain cases, however, KAsset may need to collect Sensitive Personal Data from you for providing services or products to you, for example, religion (displayed on a copy of national ID card) or race (displayed on a copy of passport of some countries), biometric data (such as facial recognition data, fingerprint recognition data, electronic signature data which uses technology extracting specific behavior of such signing for identification and authentication of the person who writes such signature, data on criminal record, health data, data on disability, sexual behavior, etc. KAsset shall collect, use and/or disclose the Sensitive Personal Data provided that KAsset has been given explicit consent by you or permitted by law. This shall be undertaken on a case-by-case basis when KAsset is required to collect Sensitive Personal Data from you.

(Unless specifically stated otherwise, personal data and Sensitive Personal Data as earlier mentioned shall hereinafter be collectively referred to as “Personal Data".)

2.3 Personal Data of minors, incompetent or quasi-incompetent persons

KAsset has no intention to collect, use and/or disclose Personal Data of minors, the incompetent or quasi-incompetent persons, unless KAsset obtains consent from the guardian, the appointed guardian, the appointed curator or any act which minors may give consent by itself pursuant to law (as the case may be) and/or has any lawful basis. If KAsset discovers that the collection, use and/or disclosure of Personal Data of minors, the incompetent or quasi-incompetent persons is undertaken without (i) consent from the guardian, the appointed guardian, the appointed curator or minors who may give consent by itself pursuant to law (as the case may be) and (ii) any lawful basis, KAsset shall delete or destroy such Personal Data.

2.4 Personal Data of any other third party

If you provide Personal Data of any other third party who is Personnel of a Juristic Person and/or is related to you to KAsset , such as shareholders, directors, authorized persons, family members, reference persons, trade partners, beneficiaries, administrators of estates, emergency contact persons, and/or any other persons identified in your transaction documents, please inform such persons of the details of this Policy and obtain their consent where necessary, or establish another lawful basis, to ensure that KAsset can collect, use, and/or disclose the Personal Data of such third parties

3. What are the objectives of collection, use and/or disclosure of your Personal Data?

KAsset will collect, use and/or disclose your Personal Data only as necessary under KAsset's legitimate objectives which include the collection, use and/or disclosure of Personal Data for compliance with the contract in which you are a contract party, for performance of duties as required by law, for legitimate interest, for operations according to your consent and/or for operations under other lawful bases. Objectives for collection, use and/or disclosure of Personal Data under this Policy are as follows.

Some of the following objectives may or may not apply to you. Please consider the objectives in accordance with your relationship with KAsset on a case-by-case basis.

3.1 Objectives requiring consent

KAsset shall collect, use and/or disclose your Personal Data based on consent for the following objectives.

       3.1.1 Collection, use and/or disclosure of Sensitive Personal Data for which KAsset cannot apply other lawful bases but must request explicit consent. Such objectives shall be:

(1) Data on religion and race (such data collected from a copy of national ID card or passport of some countries which KAsset needs to use as evidence of identification and authentication only.)

(2) Biometric data for signing, identification and authentication, electronic know your customer service of KAsset and for support of KAsset's business partners

(3) Health record data, disability data, criminal record, and sexual behavior which KAsset shall collect, use and/or disclose only when necessary for the use of certain products and/or services of KAsset only. Criminal record shall be used for examination and confiscation of related property

       3.1.2 Analyses, research and/or conducting statistical data including those for development, improvement of products and/or services of KAsset, other companies within KBank Financial Conglomerate, business partners and/or other juristic persons that require your consent in accordance with law.

       3.1.3 Marketing operations, submission of offers for products and/or services, privileges for attending activities held by KAsset, other companies within KBank Financial Conglomerate, business partners and/or other juristic persons including news, useful advice and appropriately selected promotions and launch of marketing strategies that require your consent in accordance with law.

     3.1.4 Debt collection by using location data and/or device identification data (IP address or MAC address) tracking that require your consent in accordance with law.

KAsset may request your consent directly or via other companies within KBank Financial Conglomerate, business partners and/or other juristic persons on a case-by-case basis.

3.2 Objectives requiring other lawful bases other than consent

KAsset will collect, use and/or disclose your Personal Data based on other lawful bases as necessary under KAsset's legitimate objectives, such as, for compliance with the contract in which you are a contract party or your request, for performance of duties as required by law, for the legitimate interest and/or for operations under other lawful bases for the following objectives:

     3.2.1 Operations before entering into a contract with KAsset such as giving consultation, advice and/or any other data related to products and/or services, analysis and assessment of customer demand, verification of qualification, verification of juristic person customer's status, check of data or document accuracy, identification and authentication, including know-your-customer (KYC) and customer due diligence (CDD) procedure, property assessment, examination of Sanction List of competent authorities and/or government agencies which are generally disclosed as required by law, examination of receivership or insolvency, customer risk classification, and pre-filling of customer's personal information/contact information for facilitation in applying for products and/or services of KAsset.

     3.2.2 Any operation related to consideration of products and/or service provision such as communication, receipt/delivery of documents or parcels, processing of request and operation per the request approval procedure (including but not limited to customer's property assessment, property examination and valuation, property price review),  entering into a contract, agreement and/or any other related juristic act, registration for use of products, services and/or for participation in KAsset's activities.

       3.2.3 Delivery of products and/or services under the contract you have entered into with KAsset such as

• Any operation related to the provision of products and/or services (such as account opening, change of customer information, dividend payment, return of principal, account suspension, checking investment balances, preparation of transaction reports, and preparation of customer documents required for customer transactions (such as document certification)).
• Examination, confirmation and improvement of transactions, including transactions conducted via KAsset's website and/or application
• Provision of benefits and operation in accordance with customers' benefits
• Customer relationship management, after-sale transaction operation, customer facilitation and/or management of complimentary gifts for customers
• Provision of advice or risk management guidelines
• Complaint management, solving problem, operation per customer request
• Acceptance of payment or any asset
• Monitoring compliance with conditions for use of products and/or services, termination of services.

      3.2.4 Marketing operation which does not require your consent under the law such as

• Consideration of customer groups for sending them invitation to join activities or sales promotion as appropriate
• Submission of the offering of products and/or services, privileges for attending activities, events or meeting held by KAsset, including facilitation for joining activities (such as registration for event)
• Offering of products, services and/or privileges that you have requested or notification of your benefits
• Offering of products and/or services of the same type/close to those of KAsset or other companies within KBank Financial Conglomerate which you are using
• Contact in case where you have dropped off the application for products and/or services to facilitate you in case you wish to reapply for the products and/or services of the same type with KAsset, or offering other products and/or services that you may have an interest in
• Organization of sales promotional activities (such as provision of benefits and gifts).

• Analysis, research, marketing research, conducting statistical data analysis of your financial data and/or conducting report for KAsset's internal use
• Analysis, conducting model
• Studying, analyzing and monitoring portfolio.
  

• Management, risk management, internal audit within KAsset
• Maintain legitimate benefits
• Conducting customer database or recording data in the system or database
• Regular investment plan notifications and notifications relating to investments in tax-advantaged funds.
• Satisfaction survey and assessment after use of products and/or services
• Litigation or other legal processes
• Participation, coordination and/or assignment of work to another person to perform on behalf of or in collaboration with KAsset (such as for design of products or services, design of customer service experience, design of process or support of the delivery of products and/or services)
• Assignment of rights and/or duties, management of operations of KAsset and other companies within KBank Financial Conglomerate
• Use of CCTV, control of entry/exit of KAsset's premises
• Management of complaints or management of illegal incidents or suspicious incidents (such as fraud, money laundering, terrorism and mass destruction weapon proliferation, crime, intellectual property infringement including management planning, examination, surveillance, evidence collection, reporting, and/or detection)
• Conducting database on business risk to KAsset
• IT operation, communication system management and prevention, response and mitigation of IT risk and cyber threats
• Insurance coverage for damages incurred by KAsset due to various incidents, such as fraud, cybercrime, and electronic theft.

• Compliance with orders of courts, government agencies, regulatory authorities supervising KAsset, and competent government officers under the Personal Data Protection Law, the Securities and Exchange Act, provident fund law, derivatives law, trust for capital market transactions law, taxation law, anti-money laundering law, counter-terrorism and proliferation financing law, computer crime law, bankruptcy law, and other applicable laws that KAsset  is required to comply with in Thailand and abroad, including notifications and regulations issued under such laws, whether currently effective, subsequently amended, or to be enacted in the future.

The collection, use, and/or disclosure of your Personal Data for the aforementioned purposes may involve the use of existing technologies that the bank currently has or will acquire in the future, including but not limited to blockchain technology, artificial intelligence (AI), generative AI (such as ChatGPT and Microsoft Copilot), AI chatbots technology, cloud computing, etc.

If KAsset needs to collect, use and/or disclose your Personal Data for execution of or compliance with a contract that you have entered into with KAsset and/or for KAsset's performance of duties under the law and you, upon request, do not provide such necessary Personal Data to KAsset or you have chosen to delete your user account

from the application of KAsset, KAsset may not be able to approve or deliver/provide products and/or services, either partly or wholly, for you and it may impact on KAsset's performance of duties under the law or your relationship with KAsset.

4. To whom will your Personal Data be disclosed?

Under your consent or criteria permitted by law, KAsset may disclose your Personal Data to a third party. Persons or agencies receiving such Personal Data will collect, use and/or disclose your Personal Data within the scope for which you have given consent, or within the scope related to this Policy. In certain cases, you may be under the personal data protection policy of such recipient of your Personal Data. The recipient of your Personal Data may be in Thailand or other countries.

KAsset may disclose your Personal Data to persons or agencies based on your relationship and transaction as follows:

5. Will KAsset send or transfer your Personal Data to other countries?

KAsset may need to send or transfer your Personal Data to other companies within KBank Financial Conglomerate located in other countries, or to other recipients of data, as part of KAsset's normal business operation. For instance, sending or transferring Personal Data for storage on cloud platforms or servers located in other countries, sending or transferring data of cross border fund transfer transaction to a financial institution located in another country via international funds transfer management intermediaries, a trade partner which is a private banker in another country, banks or financial institutions which are corresponding banks or nostro banks in other countries, business partners including those jointly providing products and/or services and co-branding business partners, Global Payment Networks, online social media service providers, government agencies in other countries and/or a person having connection with your transaction in other countries, etc.

If the destination country has insufficient standards of Personal Data protection, KAsset shall ensure that Personal Data will be sent or transferred in accordance with law and shall set standards of Personal Data protection as deemed necessary, and appropriate for and consistent with the confidentiality standards. For instance, an agreement must be entered into with the data recipient in that country to ensure that your Personal Data will be protected under the Personal Data protection standards equivalent to that in Thailand. If the data recipients are other companies within KBank Financial Conglomerate, KAsset may decide to conduct binding corporate rules verified and certified by relevant competent authorities and will send or transfer Personal Data to other companies within KBank Financial Conglomerate located in other countries in accordance with said binding corporate rules.

6. Use of cookies and/or technologies of similar nature

KAsset may collect and use cookies and/or other similar technologies when you use KAsset's website and/or application, including when conducting transactions and using KAsset's products and/or services through digital channels and internet networks. The collection of cookies and/or the use of other similar technologies enables KAsset to remember your usage and preferences, including analyzing your interests in order to improve and enhance the performance of KAsset's website and/or application to better respond to your needs and usage, and to ensure that you have a positive experience when using KAsset's website and/or application.

Moreover, KAsset may disclose the data that cannot identify you to data analysis service providers such as Google, both in Thailand and other countries. Google will use technologies and tools for data analysis such as cookies and/or the Software Development Kit (SDK) to monitor and conduct reports of data analysis related to your use of KAsset's website and/or application. You can learn details of Google's data analysis under the heading “How Google uses data when you use your partner's sites or apps" at http://www.google.com/policies/privacy/partners or other URL as determined by Google.

7. How long does KAsset keep your Personal Data?

KAsset will keep your Personal Data during the period you are KAsset's customer or have a relationship with KAsset, or throughout the period required in order to achieve the related objectives of this Policy. Once your relationship with KAsset ends, KAsset will further keep your Personal Data for a period as necessary according to the statute of limitations or for a period as required or permitted by law, for instance:

• Personal Data shall be kept in accordance with the anti-money laundering law for 5-10 years after the end of the relationship, as the case may be.
• Personal Data shall be kept in accordance with securities and stock exchange law, accounting law, and taxation law, for 10 years after the end of the relationship.

KAsset will undertake operations through appropriate steps to delete or destroy the Personal Data or make it anonymous when it is no longer necessary or said period ends.

8. How does KAsset protect your Personal Data?

KAsset shall apply technical, administrative and physical safeguard measures for safekeeping of your Personal Data in order to maintain confidentiality, accuracy, completeness, and availability of Personal Data to prevent unauthorized or illegitimate access, collection, revision, rectification, use and/or disclosure of Personal Data in accordance with legal requirements.

KAsset has put in place appropriate measures to prevent the infringement of Personal Data. KAsset has therefore established policies, procedures and criteria for Personal Data protection such as measures to control access to Personal Data and use of secure and proper devices for storing and processing Personal Data, restriction of access to Personal Data, determination of users'right to access Personal Data, right to permit assigned employees to access Personal Data and users' responsibilities in order to prevent unauthorized access to Personal Data, unauthorized disclosure, unauthorized knowledge or unauthorized copy of Personal Data, or theft of devices used for storing or processing Personal Data. Measures have thus been put in place for tracking back of access to, change in, deletion or transfer of Personal Data, which are consistent with and appropriate for the methods and tools for collection, use or disclosure of Personal Data, including examination for assessing the effectiveness of compliance with policies, procedures and criteria for Personal Data protection.

KAsset's executives, employees, personnel, contractors, representatives, advisors, and recipients of data from KAsset shall maintain the confidentiality of Personal Data in accordance with the confidentiality measures determined by KAsset.

9. What are your rights in connection with your Personal Data?

Your rights under this item are legal rights that you should be aware of. You can exercise your rights as stipulated by law and this Policies currently available or to be amended in the future, including criteria determined by KAsset. If you are less than 20 years old, or have limited capacity to perform juristic acts under the law, you may request your father and/or mother, appointed guardian or authorized person to express the intention to exercise these rights on your behalf.

     9.1 Right to withdraw consent (opt-out): You are entitled to withdraw the consent that you have previously given to KAsset to collect, use and disclose your Personal Data (whether such consent has been given prior to or after the personal data protection law is enforced), at any time during which your Personal Data is held by KAsset, unless there is right restriction by law or there is a contract which is beneficial to you which remains valid. The collection, use and/or disclosure of your Personal Data which was undertaken before the withdrawal of your consent shall not be affected.

However, the withdrawal of your consent related to and required for the service request may prevent KAsset from complying with the contract or providing services to you, or may cause the transaction or any other related activities to be suspended or temporarily discontinued, or may affect your knowledge of products and/or services, for instance, you may not receive the offer of products and/or services, benefits, promotions or other new offers, or may not receive alternative products or services which are more in line with your needs, or may not receive news and recommendations that are beneficial to you, etc. For your own benefit, you should determine and inquire about the potential impacts before deciding to withdraw your consent.

     9.2 Right to access: You are entitled to have access to your Personal Data under KAsset's responsibility and to request KAsset to provide you duplication of your Personal Data and inform you of how your Personal Data has been obtained.

     9.3 Right to data portability: You are entitled to request your Personal Data which has been processed by KAsset to be in a format that can be read or used in general with an automated device or equipment, and can be used or disclosed via automated methods. You are also entitled to request KAsset to send or transfer your Personal Data of said format to other data controllers if it can be processed via automated method, and to request Personal Data of said format which is directly sent or transferred by KAsset to other data controllers, unless it cannot be processed due to technical difficulties.

Your aforementioned Personal Data must be Personal Data that you have granted consent to KAsset to collect, use and/or disclose or must be Personal Data that KAsset needs to collect, use and/or disclose for your use of KAsset's products and/or services in accordance with your intention wherein you are a contract party with KAsset or for undertaking operations per your request before using KAsset's products and/or services or must be other Personal Data as determined by competent authorities.

     9.4 Right to object: You are entitled to lodge an objection to the collection, use or disclosure of your Personal Data at any time. If the collection, use or disclosure of your Personal Data, to which you lodge an objection, is undertaken under legitimate interest of KAsset or any person or any juristic person, or for public benefit, KAsset shall continue to collect, use and/or disclose your Personal Data only if KAsset can provide legal reasons that the collection, use and/or disclosure of your Personal Data is sufficiently important, or is undertaken for the establishment, defense, use of, or compliance with, the rights to claim in accordance with applicable law, as the case may be.

In addition, you are entitled to lodge an objection to the collection, use and/or disclosure of your Personal Data which is undertaken for objectives related to direct marketing or for the purpose of scientific, historical or statistical studies and research.

     9.5 Right to deletion or destruction: You are entitled to request KAsset to delete or destroy your Personal Data or make it anonymous if you believe that your Personal Data has been collected, used and/or disclosed illegitimately, which is not in compliance with applicable laws or if you deem that it is no longer necessary for KAsset to keep your Personal Data under the objectives of this Policy or when you exercise your right to withdraw consent or your right to object as mentioned earlier.

     9.6 Right to suspension: You are entitled to request KAsset to suspend the use of Personal Data if KAsset is conducting an investigation per your request to exercise your right to rectification or right to object, or for any other case wherein it is no longer necessary for KAsset to keep your Personal Data and KAsset must delete or destroy your Personal Data in accordance with applicable laws, but you have sought to request KAsset to suspend the use of your Personal Data instead.

     9.7 Right to rectification: You are entitled to rectify your Personal Data to keep it accurate, up-to-date, complete and not misleading.

     ​9.8 Right to lodge complaint: You are entitled to lodge a complaint to relevant competent authorities if you believe that the collection, use and disclosure of your Personal Data violates or does not comply with applicable laws.

Exercising the aforementioned rights may be restricted by applicable laws, and, in certain cases, there may be compelling reasons that may cause KAsset to deny your request or may prevent KAsset from complying with your request such as for in compliance with laws or court orders, for the public benefit, exercising the aforementioned rights may potentially violate other persons' rights or freedoms, etc. If KAsset denies aforementioned request, KAsset shall give you the reason(s) for such denial.

You can submit your request to exercise your rights via the following channels:

*The processing period shall be counted from the date on which KAsset has completed the verification and authentication of your identity. In cases where submission and/or delivery of supporting documents for identity verification and authentication is required, the processing period shall commence on the date KAsset receives all complete and relevant supporting documents.

10. Will KAsset rectify or revise this Policy?

KAsset may consider rectifying, revising or changing this Policy from time to time, as deemed appropriate and permitted by law. In case of rectification or revision of, or change in this Policy, KAsset will announce the current policy on KAsset's website at

https://www.kasikornasset.com/th/privacy-policy/Pages/index.aspx

11. How can you contact KAsset and the data protection officer?

If you have any suggestions or would like to inquire about information regarding details of the collection, use and/or disclosure of your Personal Data, including exercising your rights under this Policy, you can contact KAsset and/or the Data Protection Officer during KAsset's business hours (8:30 a.m. to 5:00 p.m.) via the following channels:

• K-Contact Center :

Tel. 02-673-3888

Contact address: : Kasikorn Asset Management Co., Ltd., Kasikornbank Building, 12th Floor, No. 400/22 Phahon Yothin Road, Sam Sen Nai Sub-district, Phaya Thai District, Bangkok 10400.

• Data Protection Officer:
  Email KA_DPO@kasikornasset.com.

Contact address: Kasikorn Asset Management Co., Ltd., Kasikornbank Building, 6th Floor, No. 400/22 Phahon Yothin Road, Sam Sen Nai Sub-district, Phaya Thai District, Bangkok 10400.

12. Cookies Policy

KAsset may use cookies or other similar technologies (“cookies") on KAsset's websites and/or applications to help you receive better experiences from our service and allows KAsset to improve quality of services to better serve your needs.

     12.1  What are cookies?

Cookies are small files which are downloaded to your web browsers, computer devices, internet-enabled devices, e.g. smart phone, tablet, etc. They record data and settings, e.g. your present visiting status, language setting, data related to browsing history of your preferred websites and/or applications to enable you to continuously use services that use cookies or other similar technologies.

     12.2 Benefits of cookies

Cookies help KAsset to remember which part of KAsset's website and/or applications you visited to enable KAsset to deliver using experience that is better and meets your needs, and you will be able to use the website continuously. Moreover, records of your first settings will allow you to visit the website and/or application with the same settings every time unless the cookies are removed; in which case all settings will return to the original settings.

     12.3 Types of cookies

Types of cookies that KAsset uses including but not limited to the following;

In the event that there is a connection with third-party platforms, such as advertising networks, social media platforms, or other external website providers, certain types of cookies may be managed by such third parties. Therefore, you are advised to study and understand the cookies policy and personal data protection policy of those third parties as well.

    12.4 Cookies settings and refusals

You may choose to refuse all or some types of cookies depending on your preferences by setting your browsers and/or your privacy setting. However, if you set your browser or privacy setting to refuse all cookies (including the Strictly Necessary Cookies), you may not be able to use some or all functions of the website and/or application efficiently. You may learn more details from www.allaboutcookies.org

    12.5 Change of the Policy

This Cookies Policy may be amended or changed as appropriate to comply with regulations. KAsset recommends you to check if you understand such changes. For more information on collection, use and disclosure of your personal data, rights including det ails on data controller, please visit the Privacy Policy of KAsset on the website 

    12.6 Cookies Management

• Cookies settings in Chrome
  (https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666)
• Cookies settings in Firefox
  (https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies)
• Cookies settings in Safari (https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac) and iOS (https://support.apple.com/en-us/HT201265)
• Cookies settings in Internet Explorer (https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d#ie=ie-10)