Privacy Policy

Inception Technology Co., Ltd. (the "Company") recognizes the significance of personal data protection and adhere to complying with law governing personal data protection and other related rules.

This Privacy Notice was prepared to clarify details on collection, use or disclosure of personal data, data retention period, data destruction as well as rights of personal data subject in relation to operation and service provision of LightRemit (the "Services"), which can be accessed through the website www.paypay.asia or the LightRemit Application (collectively, the "Platform"). The Company recommends you to please read and familiarize yourself with this Privacy Notice thoroughly.

Collection of personal data

The Company collects personal data from the following channels or processes:

● Personal data received from you through registration to open a user’s account,
use of the Services, visit to the Platform and contact with the Company through
various channels;

● Personal data from your account opened with third party, such as social media
accounts e.g. Facebook, Line, Instagram, etc., if you permit linkage with such accounts;

● Personal data received from companies in the Company Group;

● Personal data received from public records and non-public records which the
Company has legitimate rights to collect; and

● Personal data received from government agencies or regulators exercising legal
power.

The Company does not intend to collect personal data of children, quasi-incompetent
persons, or incompetent persons without consent from their legal parents, guardians or curators (as the case may be). If the Company perceived that the Company collected personal data from such persons without obtaining consent as required by law, the Company shall delete such personal data unless the Company is able to collect, use and/or disclose such personal data with other lawful basis other than consent or as permitted by law.

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The collected personal data

The Company may collect the various types of personal data as follows:

● Identifying data such as name and surname, gender, age, date of birth, place of
birth, copy of identification card, copy of passport, signature, occupation, name
and location of work place, education, and other data for identification.

● Contact data such as phone number, email, address, zip code, social media
username (e.g., Facebook, Instagram username or Line ID).

● Transaction and log in data such as details on purchases, transaction status,
trading history, payment, and log in.

● Financial and banking data such as net asset data, income, expenditure, credit
records, bank accounts, and banking transactions.

● Technical data such as platform visit history, patterns, or other specific data,
identification number of each computer in your network system (IP address), and
other data related to such number.

● Audio recordings such as audio recordings when you contact the Company.

● Communication data such as conversations between you and other service users
through conversation on Platform (Chat) and contacts with the Company by
telephone, email, mail or by other means.

● Data voluntarily provided by you, such as personal opinions disclosed to the
Company by you, comments or answers to the Company's survey form.

Cookies

The Company uses cookies and other tracking technologies to increase convenience and enhance experiences in your use of the Services.

Cookies are data files stored in a browser or on your device permitted by you. Cookies collect and record data about you, your device, method and time of use or visit to the Services, number of users and other activities on the Company's Platform. Cookies can remember and distinguish you from other users and help the Company to analyze and alleviate risks, prevent frauds which may occur, and increase confidence and safety on the Company's Platform.

You may refuse the use of cookies by selecting an appropriate setting in the browser or your device. However, if you refuse the use of cookies, you may not be able to use the Platform or the Services to the fullest efficiency.

Data retention period

Your personal data shall be retained as far as necessary to achieve the objective of data
collection and until there is no need for other objectives or to comply with relevant regulations. However, in case you terminate business relationship with the Company, your personal data shall be retained for a further period of 10 years after you terminate business relationship with the Company or longer as required by applicable laws, and at the end of such period the company shall delete, destroy, or anonymize the data to become anonymous data which cannot identify you.

Transfer of your personal data abroad

The Company may transfer, retain, process, and/or handle your personal data outside Thailand as necessary, including to countries that may not provide the same level of data protection as Thailand.The Company shall comply with applicable laws governing personal data protection. If the recipient country does not have appropriate level of personal data protection, the Company shall notify you of such inadequate standard and seek your consent before transferring such data.

Objectives for collection, use and disclosure of your personal data

The Company’s objectives for collection, use or disclosure of personal data as follows:

● To ensure and/or identify you when logging in to use the Services through various channels or in dealing with the Company.

● To provide Services, improve and develop Services of the Company including other potential services.

● To attend to, maintain, and carry out activities related to the Company's provision
of Services.

● To communicate, notify, and/or receive the Company’s data or changes which
occur.

● To manage risks and protect the Platform and service users, e.g. to prevent fraud, corruption, cyber threats, money laundering, etc.

● To comply with the applicable laws or requests of state agencies or regulators, e.g. reporting data to government agencies such as Bank of Thailand, Anti-Money Laundering Office or Revenue Department or when the Company receives orders from government agencies or courts, etc.

● To offer various benefits and/or other services of the Company, including
marketing promotion activities.

However, you shall be notified of other objectives not specified above when the
Company requests to collect personal data. The Company shall collect, use, or disclose
your personal data under the above objectives subject to the following lawful basis,
depending on the specific circumstance of processing:

● You have given explicit consent for the Company to process your personal data
for one or more specific purposes.

● To prepare historical document or chronicle for public interest or what related to
research or statistics. The Company shall have in place appropriate preventive measure for protection of your rights and freedom.

● As a prevention or suppression of danger to individual life, body or health.

● It is necessary to comply with agreement to which you are a party, or for use in processing as per your request before entering into the agreement.

● It is necessary for performance of duties in carrying out the missions of the
Company for public interest, or for performance of duties in exercising the power
granted by the State to the Company.

● It is necessary for legitimate interests of the Company or of other persons or
juristic persons, except if such benefits are less significant than the fundamental rights in your personal data.

● It is a compliance with law.

Disclosure of personal data

The Company may disclose your personal data from to time to the following third parties:

● Companies or affiliates in the Company Group.

● Agents, contractors or service providers who are third parties for them to provide
services to the Company and/or to you, such as service providers of fraud examination identity verification, auditors, legal advisors.

● Related government agencies or regulators such as Bank of Thailand, Anti-
Money Laundering Office, Revenue Department and any persons designated by related applicable laws or regulations.

● Third parties to exercise the Company's rights of claims or raise a defence under
a contract or pursuant to law.

● Third parties for whom the Company obtains consent from you or disclosure for
performance of transactions and/or use of Services as per your desire.

Your rights

As a personal data subject, you have the following rights:

● Right to withdraw consent. You have the right to withdraw consent to personal
data processing granted by you to the Company throughout the period during which your personal data is with the Company. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. You may withdraw your consent at any time by contacting the Company at the provided contact details or by using the available tools within your account settings on the Platform. Upon withdrawal of consent, the Company will cease processing your personal data for the relevant purposes, unless another lawful basis applies.
For marketing communications, you may withdraw your consent by using the
unsubscribe feature provided in any email communication."

● Right of access. You have the right to access and obtain a copy of your personal
data which is in the possession of the Company, including to request the
Company to disclose acquisition of your personal data.

● Right to rectification. You have the right to request the Company to rectify
inaccurate data or update incomplete data.

● Right to erasure. You have the right to request the Company to delete or
anonymize your personal data to become anonymous data which cannot identify
you. However, it must be the personal data that:
(a) Is not necessary for the objectives of the processing;
(b) You have revoked the consent granted to the Company and the Company has
no lawful basis in processing anymore;

(c) You object to the Company's processing of personal data using legitimate
interests basis;
(d) Your personal data is unlawfully processed.

● Right to restrict processing. You have the right to request the Company to restrict the use of your personal data.

● Right to data portability. You have the right to obtain your personal data in
possession of the Company in a readable form or commonly used by automated
tools or devices, which can be used or disclosed personal data by automated
means.

● Right to object. You have the right to object personal data processing by the
Company where the Company does by using legitimate interests basis, except if:
(a) The Company has a superior legitimate interests basis; or
(b) Such data processing is intended to establish, comply or use or raise a
defense against right of claim as per law. However, you may object to your personal
data processing for the marketing purpose.

● Right to lodge a complaint. Filing a complaint to related agencies in case the Company processes your personal data by violating the laws or not in
compliance with applicable laws.

The exercise of your rights referred to above may be restricted by applicable laws, and in some cases the Company may have to refuse or not be able to entertain your request to exercise the above rights. The Company shall inform you of the reasons for such refusal.

Third party’s websites

The Company's Services and Platforms may be linked to other websites which are not
operated by the Company. This Privacy Notice applies to the Company's Services and Platform only. Therefore, when visiting or using a third party’s website, you should also read declaration or policy of personal data protection applicable to such third party’s website.

Amendments

The Company reserves the right to update, change or amend this Privacy Notice in the
future under applicable laws by announcing for information through the Company’s website at www.paypay.asia or other channels such as by email or communication channel of the Company.

Contact to the Company

Should you prefer to exercise any rights referred to above or have any questions
regarding this Privacy Notice or your personal data, you may contact the Company as per the following details:

Company Name: Inception Technology Co., Ltd.
Address: 1758/4, Sukhumvit Road, Phra Khanong Tai Sub-District,
Phra Khanong District, Bangkok, Thailand, Post Code 10260
Website: https://inception.asia/
Email: dpo@inception.asia (Attend to: Mr. Pheeradech Thaweerhattananon)
Telephone: 02-003-4092