Privacy Policy

Last Updated: 31 August 2021


1.1 Zipmex Company Limited (hereinafter referred to as the ‘Company’) is a company incorporated in Thailand under the laws of Thailand which operates the website (hereinafter referred to as the ‘Website’) and/or any other platform that the Company provides (hereinafter referred to as the ‘Platforms’), dedicated to the transaction of digital assets and the provision of related services (hereinafter referred to as the ‘Services’). For convenience of wording in this Privacy Policy, the Company, this Website and/or the Platforms are referred to collectively as ‘we’ ‘us’ or ‘our’. 

1.2 All natural persons or other data subjects who log on to this Website and/or the Platforms shall be users of this Website and/or the Platforms. For convenience of wording in this Privacy Policy, the users are referred to as ‘you’ or ‘your’.

1.3 For convenience of wording in this Privacy Policy, ‘personal data’ means any information relating to an identifiable living individual who can be identified from that data or from that data and other data. 

1.4 To ensure that you have full confidence in our handling of your personal data, you are advised to read and understand the terms of this Privacy Policy in full and to periodically revisit this Privacy Policy to check for updates from time to time. In particular, by logging on to our Website and/or Platforms, regardless of whether you are registered with this Website and/or Platforms, you shall be deemed to confirm that you have read and understood this Privacy Policy.

1.5 If you visit any of the links to third-party websites and/or platforms listed on this Website and/or the Platforms or any links of any of our third-party partners, the use of your personal data will be subject to the separate and independent privacy policy of such third-party websites and/or platforms. 

1.6 This Privacy Policy is prepared in both English and Thai. In the event of any inconsistency, the English version shall prevail.

2. Purposes of the Privacy Policy

2.1 This Privacy Policy will help you understand our guidelines on protecting your personal data, and describe the rationale behind and our methods of collecting, utilizing, disclosing your personal data, as well as the cross-border transfer thereof and/or other processes involved (collectively referred to as “process”) of your personal data, and will also outline your rights in connection with such personal data as well as your options to protect such personal data when using our Services.

2.2 The Privacy Policy stipulates the types of your personal data that we may collect through your logging on to and your registration with this Website and/or the Platforms, and/or your use of the Services we offer, as well as how we shall process and protect the personal data so collected.

3. Personal Data Collected

We may collect your personal data directly through your logging on to this Website and/or the Platforms, your registration with this Website and/or the Platforms, or your use of the Services offered or provided by us. The details of such collection are as follow:

3.1 When you use this Website and/or the Platforms, we use cookies to track each of your actions and collect and retain all the information that you leave on this Website and/or the Platforms, including but not limited to your IP address, location, and other information.

3.2 If you are willing to use the Services offered by this Website and/or the Platforms, you will be required to fill in and provide the following two categories of personal data:

3.2.1 Identity Data

Such personal data can help us verify whether you are eligible to be registered as a member of this Website and/or the Platforms. It includes but is not limited to your name, residential address, mailing address, other certificates and corresponding numbers thereof that are issued by your country or government to certify your identity information, as well as all other information that can help us to verify your identity.

3.2.2 Service Data

Having the personal data will enable us to contact you and provide you with the Services. Your personal data shall include, but is not limited to, your phone number, fax number, valid email address, mailing address, and information concerning your debit card and/or other accounts.

3.3 When you use this Website and/or the Platforms or the Services that this Website and/or the Platforms offer, we may collect further personal data as required from our exclusive mailboxes or in other manners that we consider as being in compliance with relevant requirements, for the purpose of improving the functions of this Website and/or the Platforms, enhancing your experience of using this Website and/or the Platforms and its Services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.

4. Cookies

4.1 When you visit our Website and/or the Platforms, we use Google stats via cookies to record our performance and check the effects of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer’s hard drive. Only when you use your computer to access our Website and/or the Platforms can the cookies be sent to your computer’s hard drive.

4.2 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website and/or the Platforms. The information collected by cookies is non-registered and collective statistical data and does not involve personal data.

4.3 Cookies, which enable this Website and/or the Platforms or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website and/or the Platforms.

5. Purposes of Personal Data

5.1 We will process your personal data that we collect for the following purposes or in the following ways:

5.1.1 to provide you with our Services through our Website and/or the Platforms;

5.1.2 to identify and confirm your identity when you use our Website and/or the Platforms;

5.1.3 to improve and upgrade the Services of this Website and/or the Platforms (your personal data and feedback received by us can help us improve the Services of this Website and/or the Platforms, so that we can more effectively respond to your service requests and support needs);

5.1.4 to keep statistics relating to the use of our Website and/or the Platforms, and to be used for data analysis carried out in cooperation with government agencies, public affairs institutions;

5.1.5 to personalize your experience (your personal data will help us to better respond to your personalized needs);

5.1.6 to facilitate transactions (your personal data, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other third party on any grounds without your consent, except for when doing so is expressly for the purpose of completing the transaction you require);

5.1.7 to send e-mails regularly (the email address that you provide for the purpose of processing orders may be used to receive personal data on and updates to your orders, in addition to newsletters, updates, related products or services information, etc., that we may send to you from time to time);

5.1.8 to meet other purposes as specified in our agreements with you and all legal means adopted for satisfying such purposes;

5.1.9 to contact you in connection with the products and services that you may be interested in (unless you have indicated that you do not want to receive such information); and

5.1.10 to send you personalized marketing communications to ensure that you are always kept up-to-date with our latest products and services that suit your interest. 

5.2 We rely on the following legal basis to process your personal data. Not all of your personal data will apply to every legal basis stated below, and may be based upon one single or a combination of several legal basis.

5.2.1 Contractual Basis

Where we are obligated to process your personal data to carry out the responsibilities committed according to the terms and conditions of this Website and/or the Platforms. This required personal data makes up most of the data referred to in Section 3. 

5.2.2 Legal or regulatory obligations

Where we need to comply with the legal or regulatory obligations that we are subject to.

5.2.3 Legitimate interests

Where we require your personal data to achieve our legitimate interest of running our business in some specific situations, provided your interests and fundamental rights and freedoms are not overridden.

5.2.4 Consent

Where you have provided, in certain cases, your consent for us to process your personal data.

In the case where you withhold any of your personal data for us to process it in relation to the purposes prescribed in this Privacy Policy, you may not be able to utilize certain parts of our Services. In some instances, we may not be able to accept your registration for or for you to continue using our Services.

6. Disclosure of Personal Data

We may disclose your personal data to the following parties: affiliates or trusted third parties  (i) who help us operate this Website and/or the Platforms, manage our business, or provide the Services to you; (ii) when we believe that personal data disclosure is appropriate; (iii) where it is required by any of the applicable laws, regulations, rules or by any order of courts or other competent authorities; (iv) when it is necessary for executing the strategy of our Website and/or the Platforms and ensuring the proper functioning of this Website and/or the Platforms, or as may be necessary for the related parties to provide the Services, or for the protection of the rights, property or safety of us or other persons; or (v) for marketing purposes.

For the case where personal data is being disclosed to other third-parties, we will ensure the protection of your personal data, such as confidentiality arrangement, appropriate security measures to the extent as required by laws. 

7. Cross-border Transfer

For the purposes mentioned above in this Privacy Policy, we may disclose or transfer your personal data to third parties or servers located overseas which the destination countries may or may not have the same data protection standards as Thailand. In addition, we have taken steps and measures to ensure that your personal data is securely transferred, that the data recipients have suitable data protection standards in place, and that the transfer is in compliance with the laws.

8. Protection of Personal Data

8.1 We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the fullest extent possible, ensure that any personal data collected through our Website and/or the Platforms shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

8.1.1 Physical measures: records of your personal data will be stored in an appropriately locked and secured premises.

8.1.2 Electronic measures: the computer data that contain your personal data will be stored in computer systems and storage medias that are subject to strict login restrictions.

8.1.3 Management measures: only staff members duly authorized by us can access your personal data, and these staff members shall comply with our internal code concerning personal data confidentiality.

8.1.4 Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your personal data.

8.1.5 Other measures: our network servers are protected by proper ‘firewalls’.

9. Retention Period for Personal Data

We will retain your personal data for as long as it is reasonably necessary to fulfill the purposes for which we have obtained your personal data as set out in this Privacy Policy, and to establish exercise or defense of legal claims. However, we may have to retain your personal data for a longer period, if required by any applicable law.

10. Your Rights

Subject to applicable laws and exceptions thereof, your personal data rights include:

10.1 Right to Access

You have the right to request a copy of all your personal data we are processing about you.

10.2 Right to Data Portability

For the case where we have an automated platform allowing you to access your personal data automatically: (i) you may have the right to ask for your personal data to be transferred automatically to other organizations; and (ii) you may have the right to ask for your personal data to be directly transferred to other organizations, with the exceptions of cases where there are technological limitations.

10.3 Right to Object

You have the right to object to any data processing activity of your personal data in certain circumstances.

10.4 Right to Rectification

You have the right to edit your personal data to be correct and up to date.

10.5 Right to Erasure

You have the right to request the deletion or anonymization of the personal data that we process about you, in accordance with the following cases: (i) the personal data is no longer necessary for the processing purposes; (ii) once the consent has been withdrawn; (iii) you object to the processing of your personal data by us based on our legitimate interests, and we do not have overriding legitimate grounds for the processing; and (iv) the processing activity is not in accordance with the law.

10.6 Right to Restriction

You have the right to restrict any data processing activities in the following cases: (i) during the verification process in accordance with the rights request to update personal data; (ii) for cases related to personal data where initially there was a request for erasure, but this was followed by an additional request of processing restrictions instead; (iii) for cases when the data processing terms have ended, but you have requested further processing restrictions due to legal reasons; and (iv) during the process of personal data processing objection verification.

10.7 Right to Withdraw Consent

You have the right to withdraw your consent regarding the processing of your personal data at any time if such withdrawal is not restricted by law or any contract that provides benefits to you. 

10.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the competent authorities in the case that we act unlawfully or not in compliance with applicable laws in the processing of your personal data.

11. Modification to the Privacy Policy

We reserve the right to amend the Privacy Policy from time to time and at any time. We will inform you of the modifications made to the Privacy Policy by updating and publishing the effective date of the release of new versions hereof and highlighting the amendments. From time to time, we may issue a notice to inform you of a modification made to the Privacy Policy, but we are not obliged to do so. You are advised to regularly review the Privacy Policy and focus on its modifications. When an updated version of this Privacy Policy is released, your continued visit to this Website and/or the Platforms shall indicate and show that you have read and understood the terms in the updated Privacy Policy.

12. Communication with Us

If you have any requests, comments, or wish to exercise your rights under the laws, you can contact us at 15th Floor Athenee Tower, 63, Wireless Road, Lumpini Sub-district, Pathumwan district, Bangkok 10330, Thailand, or send an email to our Data Protection Officer at [email protected], which is the valid and official email through which we communicate with you.

If you have any questions regarding our Privacy Policy, you are welcome to contact us at any time.