Privacy Notice
Privacy Notice
Land and Houses Fund Management Co., Ltd. (the “Management Company”) is committed to providing you (“Customers” and/or “Business Partners”) with the best possible services. The Management Company considers the trust and confidence you place in us to be of the utmost importance. The Management Company is fully aware of the significance of protecting your personal data. Therefore, we have established policies, rules, and guidelines governing our operations, supported by strict security measures to safeguard personal data. These measures ensure that your personal data obtained by the Management Company is used in accordance with your expectations and in compliance with applicable laws.
In addition, the Management Company has implemented data security systems and stringent operational procedures, along with security measures designed to prevent unauthorized access, disclosure, use, or alteration of your information.
To ensure that you are informed about the collection, use, and/or disclosure of your personal data, your rights as a data subject, and the channels through which you may contact us for further information, the Management Company hereby provides the following details.
1. Personal Data Collected, Used, and/or Disclosed by the Management Company
“Personal Data” refers to any information relating to an individual that enables the identification of such individual, whether directly or indirectly, including:
- Identity Data: Information relating to a natural person that enables direct or indirect identification of an individual, such as first name, last name, date of birth, gender, nationality, copies of identification documents (e.g., national ID card or passport), marital status, and similar information.
- Contact Data: Such as residential address, workplace address, telephone number, and email.
- Sensitive Data: Such as religion, health information, biometric data—for example, facial recognition data collected for identity verification of applicants (including criminal records or information on offenses under relevant laws), as well as other similar data.
- Information relating to beneficiaries, such as joint fund account holders, joint fund owners and beneficiaries of the Management Company's products and services who are minors, and beneficiaries who are legal entities.
- Financial and Transaction Data: Such as bank account numbers, credit or debit card numbers, monthly income information, payment information, tax information, and similar data.
- Information regarding your use of the Management Company's products and services, such as investment simulation programs, online investment transaction services, and automated investment deduction services.
- Information related to your use of products and services that you hold with the Management Company’s marketing partners or affiliated companies, such as insurance policies, mortgages, bank deposits, savings, investments, or other financial products and services.
- Technical and Usage Data: Such as IP address, login data, website browsing information (including data collected via Cookie IDs), device type, settings, platform information, and other technologies used to access the Management Company’s website.
- Marketing and Communication Data: Your preferences regarding receiving marketing information from the Management Company and third parties, as well as records of interactions with the Management Company (e.g., recorded calls via the contact center or interactions via social media channels).
The Management Company will collect only the personal data that is necessary for providing or offering the products and/or services you request or use, including the provision of goods and/or services, payment services, and/or receiving payments. If you are unable to provide certain required personal data, it may affect the Management Company’s ability to deliver services to you, resulting in services that do not meet your needs, or the inability to offer products or services that align with your requirements, or the inability to perform contractual obligations. It may also impact compliance with applicable laws, which may carry penalties in the event of non-compliance.
The personal data that the Management Company collects, uses, or discloses may be obtained directly from you or from other reliable sources, such as government agencies, third parties related to you (e.g., employers, joint account holders), business partners, or affiliated companies. The Management Company will collect data from other sources only when your consent has been obtained as required by law, unless otherwise permitted by applicable legal exceptions.
In addition, the Management Company collects, uses, and discloses aggregated data. Such aggregated data may be derived from your personal data; however, it does not identify you as an individual. For example, the Management Company may use portions of your data that have undergone an anonymization process to calculate website access rates or generate statistical reports. The Management Company ensures that such data cannot be re-identified.
Third-party Links
Accessing the Management Company’s website may lead you to other websites through embedded links. Once you click such links and are redirected to external websites, your visit to the Management Company’s website is deemed to have ended. Those external websites may collect, use, or disclose your personal data. The Management Company is not responsible for any collection, use, or disclosure of your data by such third-party websites. Therefore, for your privacy and protection, the Management Company recommends that you read the privacy notices of every website you visit.
2. Legal Bases for Processing Personal Data
The Management Company collects your personal data for the purpose of providing or facilitating the products and/or services you request, as well as to comply with applicable laws and for other purposes specified in this Privacy Notice. The Management Company processes your personal data under the following lawful bases:
2.1 The Management Company processes data based on your Consent, which you have granted for the purpose of receiving enhanced products and/or services that better meet your needs.
2.2 The Management Company processes data under the basis of Contract, to perform actions necessary for delivering services under a contract. The Company follows internal procedures to fulfill contractual obligations, enabling you, as a contracting party, to access and use the Management Company's products and/or services.
2.3 The Management Company processes data under the basis of Legal Obligation, to comply with legal requirements, such as responding to lawful orders from competent authorities, complying with regulations applicable to financial institutions, the Securities and Exchange Act, the Anti-Money Laundering and Counter-Terrorism Financing and Proliferation of Weapons of Mass Destruction laws, and other relevant legislation.
2.4 The Management Company may process data as necessary for performing tasks carried out in the public interest or in the exercise of official authority vested in the Company (Public Task).
2.5 The Management Company processes data under the basis of Legitimate Interest, where the Company determines that such interests outweigh your fundamental rights and freedoms.
Examples of the purposes and legal bases on which the Management Company processes the personal data of customers are as follows:
| Purpose of Processing Activities | Legal Basis |
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| Provision of Products and Services by the Management Company | |
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| Marketing Activities | |
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| Business Development | |
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| Security and Risk Management | |
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| Legal Compliance Activities | |
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Examples of the purposes and legal bases on which the Management Company processes the personal data of business partners are as follows:
| Purpose of Processing Activities | Legal Basis |
|---|---|
| Provision of Goods and/or Services, Payment and/or Receipt of Payment | |
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| Security and Risk Management | |
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| Legal Compliance | |
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3. Purposes for Collecting, Using, or Disclosing Customers’ Personal Data
The Management Company collects, uses, and discloses your personal data in your capacity as a customer and/or business partner for the purpose of providing or facilitating the products and/or services you request, the provision of goods and/or services, payment and/or receiving payment services, as well as to comply with any applicable laws that the Management Company or you are required to observe, and for other purposes specified in this Privacy Notice, as follows:
- To process your purchase of products or receipt of services from the Management Company as requested by you. For example, when you register through the Management Company’s website, the Company will collect basic information such as your name, surname, email address, telephone number, and any requests or comments you provide, in order to contact you or act upon your request.
- To improve and enhance the Management Company’s services.
- To perform contractual obligations with counterparties engaged or utilized by the Management Company.
- To comply with applicable laws and regulations and/or any other purposes for which you have provided consent.
4. Details of Personal Data Disclosure
The Management Company may disclose your personal data to other parties based on your consent or under circumstances permitted by law. The recipients of such data shall collect, use, and/or disclose your personal data only within the scope of your consent or within the scope described in this Privacy Notice. Disclosure may occur under the following circumstances:
- Disclosure to shareholders of the Management Company, entities within the financial business group, or business partners of the Management Company.
- Disclosure to external service providers (Suppliers/Outsource/Service Providers) who perform data processing or other relevant functions under this law, such as agents, business partners, contractors, consultants, financial institutions, cloud computing providers, marketing service providers, and information technology development companies. These may be located domestically or internationally. Such recipients may collect and use personal data only for the purposes specified in the applicable agreement.
- Disclosure to government agencies or regulatory authorities to comply with applicable laws or official orders.
Transfer or Transmission of Personal Data Abroad
Your personal data may be transferred to and stored or processed in other countries.
Such countries may not have personal data protection standards equivalent to those of Thailand.
In such cases, the Management Company will ensure that the destination country has an appropriate level of personal data protection,
and that the transfer is lawful. The Management Company may be required to transfer personal data to fulfill contractual obligations and/or
for the legitimate interests of the Management Company, and will disclose personal data only to persons who have the right to access such data.
5. Personal Data Security Measures
The Company recognizes its duty to protect your personal data, respect your privacy, and strictly comply with applicable laws. Your personal data is classified as confidential information, and the Company implements both organizational measures and technical measures to safeguard your information, preventing unauthorized alteration, use, or access. Such measures include, for example, information system security mechanisms and customer data confidentiality policies. In addition, the Management Company has established clear duties and responsibilities for employees, staff, and external service providers to maintain the confidentiality of customer personal data in accordance with confidentiality agreements.
While the Management Company employs strict security measures, data transmission over the Internet inherently carries certain security limitations. The Company cannot guarantee the absolute security of information transmitted online. Therefore, the Management Company shall not be held liable for any direct or indirect loss or damage arising from unauthorized access to information you provide on the Company’s website, unless such unauthorized access results from the Company’s negligence.
6. Retention Period of Personal Data
The Management Company will retain your personal data for as long as necessary to fulfill the purposes for which it was collected. Personal data will be stored in accordance with the Company’s data retention policy, which prescribes a retention period of 10 years from the date your business relationship with the Company ends, for regulatory audits and legal purposes. Once the retention period has expired, the Management Company will destroy such personal data in accordance with the Company’s data disposal procedures.
7. Rights of Personal Data Subjects
You are entitled to the following rights under personal data protection laws. You may submit a request to exercise your rights through the contact channels specified under the section “9. Contact the Management Company.” We will process your request as soon as possible, within a period not exceeding 30 days.
Right to Withdraw Consent: You have the right to withdraw your consent given to the Management Company at any time, and the Company will cease processing your personal data as soon as possible. However, the Company may continue to process your personal data if there is another lawful basis for doing so, such as compliance with applicable legal requirements that necessitate data retention.
Right to Access: You have the right to request a copy of your personal data from the Management Company and to verify whether the Company processes your personal data in accordance with the law.
Right to Correction: You have the right to request that your personal data be corrected so that it is accurate, up-to-date, complete, and not misleading.
Right to Deletion: You have the right to request that the Management Company delete, destroy, or anonymize your personal data when there is no longer a legitimate reason for the Company to continue processing it. You may exercise this right together with the right to object. However, the Company may continue processing your data if it has a lawful basis for doing so.
Right to Object: You have the right to object to the processing of your personal data when such processing is carried out under the Company’s legitimate interests. You also have the right to object to the processing of your personal data for marketing purposes or profiling (automated processing used to assess aspects related to you, such as your preferences or interests for direct marketing), except in the following cases:
- When processing is necessary for the performance of a task carried out in the public interest or where the collected data is necessary for scientific, historical, or statistical research.
- When processing is necessary for the establishment, exercise, or defense of legal claims.
Right to Restrict Processing: You have the right to request the Management Company to temporarily suspend the processing of your personal data, such as when you request the Company to verify the lawful basis for processing your data. You may also exercise this right under the following circumstances:
- When you request to restrict processing based on reasons that outweigh the Company’s legitimate interests.
- When processing is no longer necessary, but retention is required for the establishment, exercise, or defense of legal claims.
Right to Data Portability: You may request the Management Company to transfer your personal data to another data controller when such transfer can be made in an automated format, or request to receive the data directly unless prevented by technical limitations.
Right to Lodge a Complaint: You have the right to file a complaint with a relevant government authority if the Management Company, its employees, or contractors violate or fail to comply with the Personal Data Protection Act.
You are responsible for ensuring that the personal data you provide to the Management Company is accurate, complete, not misleading, and always up to date.
If you wish to exercise your rights, you may submit a request through the contact channels listed in the section “9. Contact the Management Company.”
8. Other Information
Opting Out of Marketing Communications (For Customers)
You may opt out of receiving marketing communications from the Management Company by calling 02-286-3484, press 1. If you choose to opt out of marketing communications, such cancellation or refusal will not affect the services provided to you by the Management Company or any other transactions you have with the Company.
Cookies
The Management Company’s website uses cookies to improve the services provided and to create records of your visit history, without accessing the data stored on your device.
Cookies are used to distinguish you from other users, enabling the Company to provide you with a better website experience and helping the Company improve its website.
If you wish to learn how to manage cookie functions, please refer to our Cookie Privacy Notice (click here).
9. Contact the Management Company
If you wish to exercise your rights as a data subject or if you have any questions or complaints under this Privacy Notice, you may contact the Management Company through the following channels:
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Office of Land and Houses Fund Management Company Limited
1 Q.House Lumpini Building, 14th Floor, South Sathorn Road, Tungmahamek, Sathorn, Bangkok 10120 - Call Center: 02-286-3484 press 1
- E-mail: [email protected]