Privacy Notice

Siam Commercial Bank Myanmar Limited

Introduction

We, Siam Commercial Bank Myanmar Limited, a company in SCBX Group based in Thailand, together with our parent company and other companies in SCBX Group, care about the privacy of customers of SCBX Group who are protected by Thailand Personal Data Protection Act B.E. 2562 (“PDPA”), thus, we provide this privacy notice to inform our customers of our policy in relation to the collection, use and disclosure of personal data of individual (“you”) in accordance with the PDPA, relevant laws and regulations. This privacy notice informs you of how we collect, use or disclose your personal data, what and why we collect, use or disclose your personal data, how long we hold it, who we disclose it to, your rights, what steps we will take to make sure your personal data stays private and secure, and how you can contact us.

This privacy notice shall apply to customers and non-customers who are under the protection of PDPA, as follows:

Our customers
- Individual customers: Our past and present customers who are individual.
- Corporate customers:Directors, shareholders, ultimate beneficial owners, employees, guarantors, security providers, and legal representatives of our past and present corporate customers and other individuals authorised to act on their behalf. Our corporate customer shall ensure that the authorised persons and any of relevant individuals have acknowledged our privacy notice.
Non-customers
These include individuals who have no product or service holding with us, but we may need to collect, use or disclose your personal data (e.g. investors; anyone who makes a payment to or receives a payment from our customers; anyone that visits our website or our applications, branches or offices; guarantors or security providers; ultimate beneficial owner; directors or legal/authorized representatives of a company that uses our services; debtors or tenants of our customers; professional advisors, including our directors, investors, shareholders and their legal representatives, and anyone involved in other transactions with us or our customers).

Please note that some of the links on our platform may lead to third party’s platforms, and if you access these platforms, your personal data will then be processed under the third party’s policies. Make sure that you have read those privacy notices when accessing such platforms.

How we collect, use or disclose your personal data
We only collect, use, or disclose your personal data where it is necessary or there is a lawful basis for collecting, using, or disclosing it. This includes where we collect, use or disclose your personal data based on the legitimate grounds of legal obligation, performance of contract made by you with us, our legitimate interests, performance under your consent and other lawful basis. Reasons for collecting, using or disclosing are provided below:
1.1 Our legal obligation We are regulated by many laws, rules, regulations, and orders of any competent governmental, supervisory or regulatory authorities, and to fulfil our legal and regulatory requirements, it is necessary to collect, use or disclose your personal data for the following purposes, which include but not limited to:

a) compliance with the PDPA and any amendment thereof, including its sub-regulations;

b) compliance with applicable laws (e.g. Financial Institutions Business Laws, Securities and Exchange Laws, Foreign Exchange Management Law, Anti-Money Laundering Laws, Prevention and Suppression of Financial Support to Terrorism and the Proliferation of Weapons of Mass Destruction Laws, Tax Laws, and other laws to which we are subject in Myanmar, Thailand and in other countries), including conducting identity verification, background checks and credit checks, Know Your Client/Customer Due Diligence (KYC/CDD) processes, other checks and screenings (including screening against publicly available database of regulatory authorities and/or official sanctions lists), and ongoing monitoring that may be required under any applicable law; and/or

c) compliance with regulatory obligations and/or orders of authorized persons (e.g. orders by any court of competent jurisdiction or of governmental, supervisory or regulatory authorities or authorized officers).

1.2 Contract made by you with us We will collect, use or disclose your personal data in accordance with the request and/or agreement made by you with us, for the following purposes, which include but not limited to:

a) through our internal approval process and approval process of SCBX Group which can be processed wholly or partly via our internal system and/or inter-companies system connected between our system and the system of our parent company and/or the system of other companies in SCBX Group, process your request prior to entering into an agreement, consider for approval and provide products and/or services, process your applications or requests for services or products, deliver our products and/or services to you (including, MMK savings accounts - individuals and corporates, MMK current accounts - individuals and corporates with cheque, MMK fixed deposit accounts - individuals and corporates, MMK call deposit accounts – corporates, FCY current accounts - individuals and corporates with cheque, FCY fixed deposit accounts - individuals and corporates, FCY call deposit accounts – corporates, E-savings account, real time fund transfer (within SCBM), Sweep account, SCBM Business Anywhere, long-term loan including project finance loans and structured finance, overdrafts (O/D), promissory notes (P/N), letters of guarantee including but not limited to bid bonds, performance bonds, retention money bonds, payment guarantees and utility bonds, standby letters of credit , supplier/dealer financing, trust receipt financing, shipping guarantee, outward remittance (domestic and international), letters of credit issuance / amendment, inward bills for collection, outward bills for collection, outward bill under letters of credit, outward bills purchase/discount under letters of credit and bills for collection, outward bills discount without recourse under letters of credit, letters of credit advising, letters of credit confirmation, letters of credit transfer, inward remittance (domestic and international), packing credits, assignments of proceeds, supply chain, SCBM Trade Club, SCBM Trade Net, payroll (MMK and USD) – individuals, supplier payment / direct credit, direct debit and bill payment), provide advice and deal with all matters relating to the products and/or services, including any activities that if we do not proceed, then our operations or our services may be affected or we may not be able to provide you with fair and ongoing services;

b) authenticate when entering into, doing or executing any transactions;

c) carry out your instructions (e.g. to facilitate us in responding to your inquiries, to open, operate and rollover deposit accounts and/or credit facilities for you, process your application and/or your transactions, fulfil a request for utilization of products and/or services, respond to your enquiries or feedbacks, or resolve your complaints, or to generally provide you with our services and products which requires your personal information);

d) provide online banking, mobile applications and other online product platforms;

e) track or record your transactions;

f) produce reports (e.g. transaction reports requested by you or our internal reports);

g) notify you with transaction alerts;

h) recover the money which you owe (e.g. when you have not paid for your loan debt and/or outstanding fees);

i) carry out account maintenance and operations relating to your financial accounts and/or user account (if any), including without limitation, processing your applications or request for services, changing relevant information, closing account, requesting for funds from account of the deceased, processing your transactions, generating your account statement, and operating and closing your accounts;

j) carry out or make transactions and/or payments (e.g. processing payments or transactions, fulfilling transactions, conducting settlement, billing and processing activities, managing your relationship with us and administration of your account with us);

k) enforce our legal or contractual rights; and/or

l) provide IT and helpdesk supports, create and maintain code and profile for you, manage your access to any systems to which we have granted you access, and remove inactive accounts.

1.3 Our legitimate interests We rely on the basis of legitimate interests by considering our benefits or third party’s benefits with your fundamental rights in personal data which we will collect, use or disclose for the following purposes, which include but not limited to:

a) conduct our business operation and the business operation of our parent company and companies in SCBX Group (e.g. to conduct compliance audits, to conduct risk analysis and managements, to conduct finance and accounting managements, to conduct financial audits, to conduct internal operation managements, to monitor, prevent, detect and investigate fraud, money laundering, terrorism, misconduct, or other crimes, including but not limited to carrying out the creditworthiness checks of any persons related to our corporate customer, which may not be required by any governmental or regulatory authorities, and authenticating your identity to prevent such crimes);

b) conduct our relationship managements (e.g. to serve customers, to conduct customer survey, to manage customer segmentation and to handle complaints);

c) ensure security (e.g. maintain CCTV records, to register, exchange identification card and/or take photo of visitors before entering into our building areas, including but not limited to head office, branches, electronic machines (e.g. Automatic Teller Machine (ATM), Cash Deposit/Withdrawal Machine (CDM) (if any));

d) develop and improve our products, services and systems to enhance our services standard, use your personal data for conducting credit modelling, and/or for the greatest benefits in fulfilling your needs, including to conduct research, analyse data and offer products, services and benefits suitable to you by considering the fundamental rights in your personal data;

e) record images and/or voices relating to the meetings, trainings, seminars, recreations or marketing activities;

f) in case of our corporate customer, we will collect, use and disclose personal data of directors, authorized persons or attorneys;

g) ensure business continuity;

h) handle claims and disputes, including solving disputes, initiating, exercising, defending legal claims, filing lawsuits and process the relevant legal proceedings;

i) contact you prior to your entering into a contract with us;

j) evaluate suitability and qualifications of the users of the platform of the companies in SCBX Group;

k) protect against security risks (e.g. monitoring network activity logs, detecting security incidents, conducting data security investigations, and otherwise protecting against malicious, deceptive, fraudulent, or illegal activity);

l) comply with applicable foreign laws;

m) manage our infrastructure, internal control, and business operations and comply with our policies and procedures including those relating to risk control, security, audit, finance and accounting, systems and business continuity;

n) carry out research, planning and statistical analysis (e.g. data analytics, assessments, surveys and reports on our products, services and your behavior);

o) organize our promotional campaign or events, conferences, seminars, and company visits;

p) facilitate financial audits to be performed by an auditor, or receive legal advisory services from legal counsel appointed by you or us;

q) in the event of sale, transfer, merger, reorganization, or similar event, disclose or transfer your personal data to one or more third parties as part of that transaction;

r) maintain and update lists or directories of the customers (including your personal data), and keep contracts and associated documents in which you may be referred to; and/or

s) comply with reasonable business requirements (e.g. management, training, auditing, reporting, control or risk management, statistical and trend analysis and planning or other related or similar activities, implementing business controls to enable our business to operate, enabling us to identify and resolve issues in our IT systems, keeping our systems secure, and performing our IT systems development, implementation, operation and maintenance).

1.4 Your consent In certain cases, we may ask for your consent to collect, use or disclose your personal data to maximise your benefits and/or to enable us to provide services to fulfil your needs for the following purposes, which include but not limited to:

a) collect, use, and disclose your sensitive personal data as necessary (e.g. to use your identification card and/or passport photo (which may contain your sensitive personal data, namely religion and/or blood type) and criminal record for verification of your identity before continuing the transaction, and Know Your Client (KYC) process and/or health and disability data (e.g. physical wellbeing and soundness of mind) for evaluating your suitability, vulnerability, and qualifications for investment);

b) collect and use your personal data and any other data to conduct research and analyze for the greatest benefits in developing products and services to truly fulfil your needs and/or to contact you for offering products, services and benefits exclusively suitable to you;

c) send or transfer your personal data and sensitive personal data to any country outside Thailand, which may have inadequate personal data protection standards (unless the PDPA specifies that we may rely on other legal basis or may proceed without obtaining consent);

d) disclose your personal data and any other data to other companies in SCBX Group as shown on https://www.scb.co.th/en/about-us/affiliates-financial-business-group.html and our trusted business partners for the following purposes: (1) researching, conducting statistical data, developing, analyzing products, services, and benefits to fulfil your needs; and (2) contacting you for offering products, services and benefits exclusively suitable for you; and/or

e) other activities which we may require your consent.

1.5 Other lawful basis Apart from the lawful basis which we mentioned earlier, we may collect, use or disclose your personal data based on the following lawful basis:

a) prepare historical documents or archives for the public interest, or for purposes relating to research or statistics;

b) prevent or suppress a danger to a person’s life, body or health; and/or

c) necessary to carry out a public task, or for exercising official authority.

If the personal data we collect from you is required to meet our legal obligations or to enter into an agreement with you, we may not be able to provide (or continue to provide) some or all of our products and services to you if you do not provide your personal data when requested.

What personal data we collect, use or disclose
The type of personal data, namely personal data and sensitive personal data, which we collect, use or disclose, varies based on the scope of products and/or services that you may have used or had an interest in. The type of personal data and sensitive personal data shall include but not limited to:

Category	Examples of personal data
Personal details	Title Given name, middle name, surname, hidden name (if any) Gender Date of birth Place of birth Age Educational background Marital status Nationality Partner and children details
Contact details	Mailing address Residential address E-mail address Phone number Mobile number Facsimile Number Name of representatives or authorised persons/directors acting on behalf of our customers Social media accounts/ID and other electronic communication ID, including profile data, photo and other identifier for electronic communication Business address Business phone number Contact details of reference person
Identification and authentication details	Photo ID card photo or passport photo Identification number Passport information Driving licence Signatures Tax identification number House registration
Employment details	Occupation Employer’s details Position Salary or income Remuneration Job title Bonus Work place Professional background
Financial details and data relating to your relationship with us	Data relating to products and/or services you use (e.g. data relating to accounts and credit facilities) Channels you use and ways you interact with us Your customer status, your ability to get and manage credit facilities, your payment history, transaction records Data relating to your transactions Credit card and debit card information Account number and account type Account history Current assets Income and expenses Payment details
Market research, marketing and sales information	Customer survey Data and opinions expressed when participating in market research (e.g. responses to questionnaires, surveys, requests for feedback, and research activities) Details of services you receive and your preferences Inferences about you based on your interactions with us Communication preferences and details or content of your communications with us
Geographic information, information about your device and your software, and technical details	Location of our branches or ATMs you use Your GPS location IP address Technical specifications and uniquely identifying data (e.g. web beacon, log, device ID and type, network, location, IMEI (International Mobile Equipment Identity) of mobile phone or other unique device identifier, connection details, access details, single sign-on (SSO) details, login log, access times, time spent on our page, cookies, login data, search history, browsing details, browser type and version, time zone setting and location, language preferences, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access the platform)
Investigation data	Due diligence checks (e.g. data relating to Know Your Client (KYC) or Customer Due Diligence (CDD)) Data for risk management or Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) checks
User login, subscription data, and profile details	Login data for using our system, online internet banking, and applications Account identifiers Username and password Interests, preferences and activities
Usage details	Data relating to your usage of websites, platforms, products and services Data relating to your usage and interaction with our advertising (including content viewed, links clicked, and features used)
Spouse details	Title Given name, middle name, surname, hidden name (if any) Marital status Number of persons in responsible (if any) Nationality Identification number Date of birth Income
Loan details	Name of corporate/individual borrower and guarantor and their information (e.g. address, telephone number, fax number and bank account information) Collateral provider’s details and value of collateral Name and surname of authorized person and contact person of the borrower, the guarantor or the collateral provider Signature of authorized person Identification documents (e.g. Identification card, passport of authorized person and contact person) Transaction information (e.g. loan amount, guarantee amount, account number etc.)
Letter of guarantee and standby letters of credit details	Beneficiary information (e.g. name, company name, address, telephone number, fax number and bank account information) Transaction information (e.g. SWIFT CODE and account number and amount)
Trade finance service details	Applicant information (e.g. name, address, telephone number and email address) Beneficiary, assignee and customer information (e.g. name, address, telephone number, email address and account number) Name and surname of authorized person and contact person Signature of authorized person Identification documents (e.g. Identification card, passport of authorized person and contact person) Transaction information (e.g. loan and transaction amount, guarantor name and guarantee amount, account number, cheque number, payment condition, vessel and carrier’s name, trade documents etc.)
Information concerning security	Visual images Personal appearance Detection of any suspicious and unusual activity CCTV images or recordings Video recordings
Sensitive personal data	Religion as shown in the identification card and/or passport Blood type as shown in the identification card and/or passport Criminal records Health data (e.g. data relating to weight, height, heart rate) Disability data
Other information	Records of correspondence and other communications between you and us, in whatever manner and form, including but not limited to phone, email, live chat, instant messages and social media communications Data that you provide to us through any channels

Sources of your personal data
Normally, we will collect your personal data directly from you (e.g. through our branches, relationship managers.), but sometimes we may get it indirectly from other sources (e.g. social media, third party’s online platforms, or other publicly available sources) or through our parent company and other companies in SCBX Group, service providers, business partners, and/or any other persons who we have legal relationship with, official authorities, financial institutions, credit bureau, persons related to you (e.g. your family, friends, referees) or third parties (e.g. your beneficiaries, sellers, buyers, carriers, nominated banks, representatives, employers, sponsors, our corporate customers as you are a shareholder, director, authorised person, attorney, representative or contact person and third parties that have roles in delivering services to you (e.g. data that is publicly available, data that relates to transactions, credit data) or someone acting on their behalf may provide us with information about you), in such case we will ensure the compliance with the PDPA. In case you have given any personal data of any other person to us in executing transactions with us or any purposes, you shall notify such person of the details relating to the collection, use and disclosure of personal data and rights under this privacy notice. In addition, you shall obtain consent from such person (if necessary) or relied on another legal basis to provide personal data to us.
Your rights
The PDPA aims to give you more control of your personal data. You can exercise your rights under the PDPA upon the effectiveness if the provisions are in relation to the rights of data subjects, details are as follows:
4.1 Right to access and obtain copy

You have the right to access and obtain copy of your personal data held by us, unless we are entitled to reject your request under the laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.

4.2 Right to rectification

You have the right to rectify your inaccurate personal data and to update your incomplete personal data.

4.3   Right to erasure

You have the right to request us to delete, destroy or anonymise your personal data, unless there are certain circumstances where we have the legal grounds to reject your request.

4.4   Right to restrict

You have the right to request us to restrict the use of your personal data under certain circumstances (e.g. when we are pending examination process in accordance with your request to rectify your personal data or to object the collection, use or disclosure of your personal data, or you request to restrict the use of personal data instead of the deletion or destruction of personal data which is no longer necessary but you ask us to restrict it instead as you have necessity to retain it for the purposes of establishment, compliance, exercise or defense of legal claims).

4.5   Right to object

You have the right to object the collection, use or disclosure of your personal data in case we proceed with legitimate interests basis or for the purpose of direct marketing, or for the purpose of scientific, historical or statistic research, unless we have legitimate grounds to reject your request (e.g. we have compelling legitimate ground to collect, use or disclose your personal data, or the collection, use or disclosure of your personal data is carried out for the establishment, compliance, or exercise legal claims, or for the reason of our public interests).

4.6   Right to data portability

You have the right to receive your personal data in case we can arrange such personal data 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. Also, you have the right to request us to send or transfer your personal data to third party, or to receive your personal data which we sent or transferred to third party, unless it is impossible to do so because of the technical circumstances, or we are entitled to legally reject your request.

4.7 Right to withdraw consent

You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us, unless the nature of consent does not allow such withdrawal. The withdrawal of consent will not affect the lawfulness of the collection, use, or disclosure of your personal data based on your consent duly given before it was withdrawn.

You can review and change your consent to use or disclose your personal data for marketing purposes through channels as specified in No. 11 below or through other channels prescribed by us in the future.

4.8   Right to lodge a complaint

You have the right to make a complaint with the Personal Data Protection Committee or their office in the event that we do not comply with the PDPA.

How we share your personal data
We may disclose your personal data to the following parties under the provisions of the PDPA:
a) our parent company and other companies in SCBX Group, business partners and/or other persons that we have the legal relationship, including our directors, executives, employees, staffs, contractors, representatives, advisors and/or such persons’ directors, executives, employees, staffs, contractors, representatives and advisors;

b) governmental authorities and/or supervisory or regulatory authorities, whether they are in Myanmar or Thailand (e.g. the Bank of Thailand, Ministry of Digital Economy and Society, Anti-Money Laundering Office, Thai Revenue Department, Central Bank of Myanmar, Myanmar Financial Intelligence Unit, Myanmar Credit Bureau and Ministry of Planning and Finance of Myanmar);

c) suppliers, agents and other entities (e.g. professional associations to which we are member, external auditors, depositories, document warehouses, overseas financial institutions and clearing houses, where the disclosure of your personal data has a specific purpose and under lawful basis, as well as appropriate security measures);

d) any relevant persons as a result of activities relating to selling rights of claims and/or assets, restructuring or acquisition of any of our entities, where we may transfer our rights to; any persons with whom we are required to share data for a proposed sale, reorganisation, business transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets used in our business operation;

e) other banks, financial institutions and third parties where required by law to help recover funds that have entered your account due to misdirected payment(s) by such third parties or trace funds where you are a victim of suspected financial crime, or where suspect funds have entered your account as a result of financial crime;

f) debt collection agencies, lawyers, credit bureau, fraud prevention agencies, courts, authorities or any persons whom we are required or permitted by laws, regulations, or orders to share personal data;

g) third parties providing services to us (e.g. IT service providers, market analysis and benchmarking service providers, cloud computing service providers, including but not limited to correspondent banking, agents and subcontractors acting on our behalf, the companies which print and deliver credit card statements);

h) social media service providers (in a secure format) or other third-party advertisers so they can display relevant messages to you and others on our behalf about our products and/or services. Third-party advertisers may also use data relating to your previous online activities to tailor adverts to you;

i) third-party security providers;

j) other persons that provide you with benefits or services associated with our products or services; and/or

k) your attorney, sub-attorney, authorized persons or legal representatives who have lawfully authorized power.

International transfer of personal data
The nature of the modern banking business is global and under certain circumstances it is necessary for us to send or transfer your personal data internationally (e.g. transferring data to our parent company and other companies in SCBX Group or to cloud server overseas for the purpose of the provision of services). When sending or transferring your personal data, we will always exercise our best effort to have your personal data transferred to our reliable business partners, service providers or other recipients by the safest method in order to maintain and protect the security of your personal data. If the destination countries do not have adequate data protection standard, we will proceed to transfer personal data as specified by the PDPA and will put in place the protection measures of such personal data as necessary and appropriate.

Retention period of personal data
We will maintain and keep your personal data while you are our customer and once you has ended the relationship with us (e.g. after you closed your account with us, or following a transaction with us, or in case of your application to use our services is disapproved, or you terminated the services provided by us), we will only keep your personal data for a period of time that is appropriate and necessary for each type of personal data and for the purposes as specified by the PDPA.

The period we keep your personal data will be linked to the prescription period or the period under the relevant laws and regulations (e.g. Financial Institution Business Laws, Securities and Exchange Laws, Securities and Exchange Laws, Foreign Exchange Management Law, Anti-Money Laundering Laws, Prevention and Suppression of Financial Support to Terrorism and the Proliferation of Weapons of Mass Destruction Laws, Accounting Law, Tax Laws, Labour Laws and other laws to which we are subject in Myanmar, Thailand and in other countries). In addition, we may need to retain records of CCTV surveillance in our premises or at ATM machines and/or voice records of Call Center to prevent fraud and to ensure security, including investigating suspicious transactions which you or related persons may inform us.
Use of Cookies
We may collect and use cookies and similar technologies when you use our products and/or services. This includes when you use our websites and internet banking.

The collection of such cookies and similar technologies helps us recognise you, remember your preferences and customise how we provide our products and/or services to you. We may use cookies for a number of purposes (e.g. enabling and operating basic functions, helping us understand how you interact with our websites or emails, or enabling us to improve your online experiences or our communications with you, particularly, to ensure that online adverts displayed to you will be more relevant to you and of your interests), for details, please see our Cookie Notice .
Use of personal data for original purposes
We are entitled to continue collecting and using your personal data which has previously been collected by us before the effectiveness of the PDPA in relation to the collection, use and disclosure of personal data in accordance with the original purposes. If you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time.
Security
We endeavour to ensure the security of your personal data through our internal security measures and strict policy enforcement. The measures extend from data encryption to firewalls. We also require our staff and third-party contractors to follow our applicable privacy standards and policies and to exercise due care and measures when using, sending or transferring your personal data.
How to contact us
If you have any questions or would like more details about our privacy notice or would like to exercise your rights, please contact us through phone number +95-9-774 55555 9; +95-9-773 999919.

Alternatively, you can contact our representatives who are responsible for Data Protection Officer by writing to E-mail: info.scbm@scbmm.com or contact our head office located at Sule Square Office Tower, No. 221, Level 18, Unit 06-07, Sule Pagoda Road, Kyauktada Township, Yangon, Myanmar.
Changes to this privacy notice
We may change or update this privacy notice from time to time and we will inform the updated privacy notice at our website www.scbmm.com.

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Siam Commercial Bank Myanmar Limited

Introduction