HaoTrust Capital Investments Co., Ltd Privacy Policy
1. Purpose
Your Privacy is important to Us
In this policy, “we”, “us”, “our” or “HAOTRUST” means HaoTrust Capital Investments Co., Ltd, and/or “you”, “your” or “yours” means the persons to whom this policy applies and “The Trustee” means HaoTrust Capital Investments Co., Ltd, its related corporations, affiliates and branches.
HAOTRUST has established this Privacy Policy in order to protect the personal data stored with us and to govern the use of information received or collected by The Trustee.
2. Scope
This policy applies to any individual’s personal data which is in our possession or under our control.
In the event of any inconsistency between different versions of this policy, the English version shall prevail.
3. Collection of Personal Data
We define “Personal data” as data that can be used to uniquely identify a natural person. Personal data can be collected from various sources and processed by us. Some examples of data which on its own or jointly, can be used to identify a natural person are:
- Personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
- Specimen signature(s);
- Financial details (e.g. income, expenses, and/or credit history);
- Images and biometrics such as thumbprints, voice and video recordings of you, including our conversations with you for verification or other purposes;
- Employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- Tax and insurance information;
- Information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- Trust information (e.g. account numbers and trust transactions);
- Your personal opinions made known to us e.g. through feedback or surveys;
- Information relating to your activities, habits, preferences and interests arising from your use of products and services of the Trustee, our partners or vendors; and/or
- Other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.
4. Use of Personal Data
We may use your personal data for our business purposes, such as:
- Providing trust instruments, and developing products or services (whether made available by us or through us), including but not limited to:
- executing investments, trust instruments, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis; or
- analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customization strategies.
- Assessing and processing applications, instructions or requests from you:
- Communicating with you, including providing you with updates on changes to products, services and trust instruments (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services, trust instruments, their terms and conditions; and other marketing purposes such as special offers, promotions, contests, or entitlements that may be of interest to you or which you may be eligible.
- Managing our infrastructure, business operations and complying with internal policies and procedures;
- Responding to queries or feedback;
- Addressing or investigating any complaints, claims or disputes;
- Verifying your identity for the purposes of providing trust instruments, products or services;
- Conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- Complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- Monitoring products and services provided by or made available through us;
- Complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- Creating and maintaining credit and risk related models;
- Financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- Enabling any actual or proposed assignee or transferee, participant or sub-participant of HaoTrust’s rights or obligations to evaluate any proposed transaction;
- Enforcing obligations owed to us;
- In connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or
- Administering benefits or entitlements in connection with our trust relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards.
- Providing trust instruments, and developing products or services (whether made available by us or through us), including but not limited to:
In addition to the above purposes, we may also use personal data for purposes set out in the terms and conditions that govern our relationship with you.
5. Disclosure and Sharing of Personal Data
We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of the HaoTrust or to third parties, whether located in Cambodia or elsewhere, in order to carry out the purposes set out above in section 4. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.
For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or as our customer. You may also contact us for more information (please see the “Contact us” section below).
We wish to emphasise that HaoTrust does not sell personal data to any third parties, and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.
We may transfer, store, process and/or deal with your personal data outside Cambodia. In doing so, we will comply with the Law on Trust, Consumer Protection Law of Cambodia (CPL) and other applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (GDPR).
6. Cookies and Related Technologies
Our websites and mobile applications (“apps” or an “app”) use cookies. A cookie is a small text file placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet Protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.
A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
You have the choice to set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, do note that when you enable blocking of cookies and pixel tags, it may limit certain features and functions in your use of our websites or applications.
The HaoTrust will take necessary measures to prevent the leakage loss of the information collected through HaotTrust server.
7. Other Websites
Our websites may contain links to other websites which are not maintained by HaotTrust. This privacy policy only applies to the websites of HaotTrust.
The HaotTrust is not responsible for the privacy practices or content of such websites therefore, when visiting these third party websites, you should read their privacy policies which will apply to your use of the websites.
8. Retention of Personal Data
Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.
9. Access and Correction
You may request access or make corrections to your personal data held by HaotTrust. HaotTrust may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
There are also other data protection and privacy laws that provides relevant individuals with additional rights including the right to obtain information on how HaotTrust process your personal data, receive certain information provided in an electronic format and/or request that these be transmitted to a third party, request for your information to be erased, object or restrict the use or processing of your information in some circumstances e.g. GDPR. These will be subject to ongoing obligations imposed on the Trustee pursuant to any applicable law or regulation, and/or the Trustee’s legitimate reason or entitlement to continue processing your information, and/or to refuse that request.
Please contact us (please see the “Contact us” section below) for details on how you may request access, correct or exercise your rights with respect to the processing of your personal data.
10. Contact Us
To contact us on any aspect of this policy or your personal data or to provide any feedback that you may have, please visit any of our branches or get in touch with our customer centre officer in the following ways:
If you are our customer or a non-customer, you may contact our customer centre officer at our 24-hour hotline at (855) 23 235555 or email us at info@haotrust.com.kh
In addition, should we be aware that your data has been compromised and is, or likely to result in significant harm to you, we will notify you and advise on the possible steps to protect yourself from further potential harm. Please be assured that you can always validate such notifications from us by contacting us at our 24-hour hotline at (855) 23 235555 or email us at info@haotrust.com.kh
11. Amendments and Updates of HAOTRUST Privacy Policy
We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way HAOTRUST uses your personal data or any changes to the laws and regulations applicable to HAOTRUST. We will make available the updated policy on our website (www.haotrust.com.kh/privacy) and at our branches in Cambodia. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.
