Advisory Alliance And Partners Company Limited
https://fynncorp.com
1.1 Advisory Alliance And Partners Company Limited (“AA&P” or “we”) has established and discloses this privacy policy statement (the “Privacy Policy Statement”) as our approach to explain how we, as the data controller, collect, use, disclose or otherwise process personal information of our existing customers and prospect customers, and how we protect personal information and properly handle such information once the provisions under the Personal Data Protection Act B.E. 2562 (2019) (the “PDPA”) with respect to the processing of personal information become effective.
1.2 AA&P recognizes the importance of protecting personal information, and complies with the PDPA and other relevant laws and regulations as well as internal regulations of AA&P including this Privacy Policy Statement, and AA&P strives to properly protect and handle personal information.
1.3 AA&P collects personal information through appropriate and lawful means, and only to the extent necessary to achieve the purpose of utilization. Such collection, use, disclosure or otherwise processing of personal data will be in accordance with the provisions of relevant laws only.
1.4 AA&P specifies the purpose of collection, use, disclosure or otherwise processing of personal information, and collects such information to the extent necessary in relation to the purpose. In cases where the purpose of collection, use, disclosure or otherwise processing of specific personal information is limited by relevant laws and regulations, AA&P does not use such personal information beyond such limitations of the purpose. You may find details of purpose of collection, use, disclosure or otherwise processing of personal information in this Privacy Policy Statement.
1.5 AA&P does not disclose personal information to any third party, except where the person concerned has granted prior consent in that regard, or where disclosure of personal information is based on laws.
1.6 AA&P takes appropriate security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction or disclosure, of personal information. When appointing any third party to process personal information on behalf of AA&P, AA&P appropriately oversees such third party.
1.7 AA&P reviews the content of this Privacy Policy Statement as necessary, and strives to bring about continuous improvement such as to our systems and approaches for protecting personal information.
1.8 AA&P trains and educates our officers and employees regarding the importance of protecting personal information to ensure that they handle customers’ personal information in an appropriate manner.
1.9 AA&P responds in an appropriate and swift manner to requests for exercising data subject rights, any opinions or requests concerning its collection, use, disclosure or otherwise processing of personal information. Please see relevant details shown in this Privacy Policy Statement or please contact AA&P at contact details shown below.
2.1 What is personal information?
Personal information means any information relating to an individual, which enables the identification of such individual, whether directly or indirectly,
2.2 Personal information we collect, use, disclose or process
AA&P collects several types of personal information, including:
– Identity data (for example, name, surname, identification card number, passport number, birthdate, gender, nationality, marital status, online identity (e.g. IP address, cookie, device ID), and in some cases AA&P may process sensitive data such as biometric data for face recognition only with your explicit consent or when permitted by law)
– Contact data (for example, address, telephone number, email)
– Transaction data (for example, credit card number, member card number, income information, financial statement, data of transaction via AA&P products or services, credit history, debt payment history, asset information)
– Communication data (for example, images, video or voice recordings when communicating with us)
2.3 Sources of information
AA&P may collect your personal information from various sources as follows:
(1) Collect information directly from you, for example:
– Procedures for applications for using our services, contract signing, form filling, questionnaires, registrations or submission of claims or requests
– Your communication with us via our contact channels, e.g. telephone, e-mail, etc.
– Automatic system, e.g. when you use our website or application, etc.
(2) Collect information from other sources, for example:
– Our customers, agents or service providers
– Our group companies or our business partners
– Government authorities or other publicly available sources, such as company website, information made available on the internet or social media platforms (e.g. Facebook, Twitter, LinkedIn, etc.)
AA&P collects, uses, discloses or processes your personal information for various purposes depending on relationship between you and AA&P as follows:
| Processing Purposes | Lawful Basis |
| To consider applications for using our products or services | Performance of a contract or taking steps at your request before entering into a contract |
| To conduct e-KYC authentication for verifying customer identity | Consent |
| To conduct KYC authentication for verifying identity | Compliance with a law |
| To use our products or services and comply with our internal procedures (e.g. delivery of documents between you and AA&P). | – Performance of a contract – Legitimate interest |
| To evaluate, improve and develop our products, services and sales promotion. | – Legitimate interest – Consent |
| To comply with legal obligations and law enforcement requests, and to report information to government authorities as required by laws (e.g. Bank of Thailand, Revenue Department) or upon receiving an order or a writ of attachment from police officers, government authorities or courts. | Compliance with a law |
| To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims | Legitimate interest |
| To conduct business planning, reporting, and forecasting | Legitimate interest |
| To prevent and detect fraud, money laundering, financing of terrorism and other illegal actions | – Performance of a contract – Compliance with a law – Legitimate interest |
| To trace and collect debts | – Performance of a contract – Legitimate interest |
| To legally assign any rights, duties and benefits under contract between you and AA&P, including transfer or selling of debts or transfer due to securitization | – Performance of a contract – Legitimate interest |
| To support inspection, investigation or other legal proceedings | – Performance of a contract – Legitimate interest |
| To monitor security in and around our head office, regional offices, branches or premises, including ID card deposits when entering our premises and using CCTV to collect videos of those who contact in person | Legitimate interest |
| To manage risks and undertake internal audit and administration | Legitimate interest |
| To manage our relationship with you, for example to manage claims, to offer benefits without marketing purposes | – Legitimate interest – Consent |
| To analyze, research and develop our products and services to meet your requirements | Consent |
| To analyze your spending or service using history and your preferences to enhance benefits and offering our products or services available currently and, in the future, | Consent |
| To inform you of benefits and sales promotion for marketing purposes, to send activity invitations, to inform product or service information, including other notifications without marketing purpose | – Consent – Legitimate interest |
| To verify customer’s identity for access to AA&P lounge | Consent |
| To offer insurance products | Consent |
| To disclose to our agencies, contractors/sub-contractors and/or service providers for their implementation and procedure | – Performance of a contract or taking steps at your request before entering into a contract – Compliance with a law – Legitimate interest |
| To disclose to our co-branded partners and business partners in order to enhance benefits and offering of existing and developing products or services of AA&P and our co-branded partners and business partners, and to inform benefits and sales promotion | Consent |
| To disclose to our group companies and business partners for marketing purposes, including offering products, services, benefits and other special offers | Consent |
AA&P retains your personal information for as long as is considered necessary for the purpose for which it was collected, used, disclosed or processed as set out in this Privacy Policy Statement. The criteria used to determine our retention periods include: (i) we retain the personal information for the duration we have an ongoing relationship with you and provide the service to you; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be complied with, for any other cause, our internal policies and regulations.
AA&P may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Policy Statement, to:
5.1 Our subsidiaries, affiliates and any related companies for business purposes, internal management, offering for services which you may be interested in, including undertaking any other activity as set out in this Privacy Policy Statement
5.2 Government authorities, supervising authorities or other authorities as stipulated by laws, including competent official, e.g., courts, police officers, Securities and Exchange Commission, Bank of Thailand, Anti-Money Laundering Office, Revenue Department.
5.3 Agencies, contractors/sub-contractors and/or service providers for their implementation and procedure, such as
– Carriers, providers of card issuing or destruction, document storage and destruction service providers, printing house, marketing agency, research companies, IT development companies
– Debt collection service provider (in the case where AA&P assigns such debt collection service provider for trace and collection procedure and/or legal execution)
– National Credit Bureau Company Limited
– Auditors, lawyers, legal advisers, and consultants
5.4 Assignees of AA&P’ rights, duties and benefits, including their attorneys, for example in case of corporate restructuring, merger, acquisition, sale of assets, debt transferring or selling, securitization, etc.
5.5 Co-branded partners and business partners of AA&P or other third parties as per your consent or contractual requirements or legal requirements, as the case may be
6.1 Your rights under the PDPA
According to the PDPA, you have certain rights relating to your personal information as follows:
(1) Right to Withdraw Consent
You have the right to withdraw consent given to us for collecting, using or disclosing your personal information at any time, unless there is a restriction of the withdrawal of consent by law or the contract which gives benefits to you.
However, the withdrawal of consent shall not affect the collection, use or disclosure of personal information you have already given consent legally. In addition, where you withdraw consent, you may experience less convenience in using our products or services, or may not receive our benefits or special offers.
(2) Right to Access
You have the right to request access to and obtain a copy of your personal information, which is under our responsibility, or to request the disclosure of the acquisition of the personal information obtained without your consent. At our discretion, we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal information, we may charge a reasonable processing fee.
(3) Right to Data Portability
Where AA&P arranges your personal information to be in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means, you have the right to receive your personal information and are also entitled to:
(a) request us to send or transfer your personal information in such formats to other data controllers if it can be done by the automatic means;
(b) request to directly obtain your personal information in such formats that we send or transfer to other data controllers, unless it is impossible to do so because of the technical circumstances.
(4) Right to Object
You have the right to object to the collection, use, disclosure or otherwise processing of your personal information for direct marketing purposes or on grounds stipulated by law. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process your personal information for the establishment, exercise or defense of a legal claim.
(5) Right to Erasure
You have the right to request AA&P to erase, destroy or make your personal information become unidentifiable data, under certain circumstances unless we are required to retain your personal information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
(6) Right to Restriction of Processing
You have the right to request AA&P to restrict the use of your personal information under certain circumstances where you believe such personal information to be inaccurate, our processing is unlawful; or we no longer need to process such personal information for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
(7) Right to Rectification
AA&P will ensure that your personal information remains accurate, up-to-date, complete, and not misleading. However, if you consider that your personal information is inaccurate or changed, you have the right to request AA&P to rectify your personal information to be accurate, up-to-date, complete, and not misleading.
6.2 How to exercise your rights
You may exercise the data subject rights listed above via the following channels:
– Privacy setting page (via this website)
– Contact Center at 02-126-8151 for (1)Right to Withdraw Consent and (7)Right to Rectification
– Other channels as specified in Clause 8 below for your right (2)-(6)
Nonetheless, if we reject your request, we will inform you of the reasons.
6.3 Processing time
AA&P will process your request within 30 days upon receipt of your valid request together with complete supporting documents. Until then, your personal information will still be unchanged in our database and may still be processed or you may be contacted by us, our partners or those who have retained your personal information as of the date of your request.
7.1 Implementation of Security Measures
AA&P implements appropriate security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of personal information.
7.2 Disclosure of Personal Information to Data Processor
AA&P properly supervises third parties to which AA&P has appointed to process personal information pursuant to our orders or on our behalf.
If you have any questions or inquiries about the protection of your personal information, collection, use or disclosure of your personal information, or exercise of your rights, or have any claims, please contact us at:
Advisory Alliance And Partners Company Limited and Data Protection Officer
63 Suite No. 65 Athenee Tower, 23rd Floor, Wireless Road, Lumpini, Pathumwan, Bangkok 10330
Tel: Office 02-126-8151
E-mail: partners@advisory-alliance.com
You also have the right to file a complaint with the relevant Personal Data Protection Committee if AA&P violates or do not comply with the PDPA or other regulations or notifications issued in accordance with the PDPA.
This Privacy Policy Statement applies to the sales of products or provision of services and use of website of AA&P only. When you link to third party websites via AA&P Website, the personal information protection shall be in accordance with the privacy policy statement of such third-party websites which are not related to AA&P.
AA&P regularly reviews and, if appropriate, updates this Privacy Policy Statement from time to time to ensure that your personal information is properly protected. In case of any update to this Privacy Policy Statement, AA&P will inform you through Privacy Policy Statement on this website or other appropriate methods. Please refer to this page for the updated Privacy Policy Statement.
[Last updated on August 2021]