Privacy Policy | Vailor Capital

VAILOR CAPITAL values and respects your privacy rights and the security of your Personal Data. As such, we have set strict policies, regulations and operating criteria for VAILOR CAPITAL in order to protect your Personal Data. This ensures that your Personal Data will be used correctly and lawfully according to your intentions.

1. What is The Purpose of This Policy?

The purpose of this policy is to inform you, as a Data Subject, about the purposes and details of collection, use and/or disclosure of your Personal Data along with the legal rights of the Data Subject.

2. Definitions under This Policy

"Employee"	means	an employee of VAILOR CAPITAL.
"Data Subject"	means	an individual identifiable by Personal Data (who is not a real rights holder or who is the creator of such data).
"Personal Data"	means	any information relating to a natural person, which enables the identification of such natural person, whether directly or indirectly, but not including information about deceased persons.
"Sensitive Personal Data"	means	Personal Data which requires particularly careful handling, such as data regarding ethnicity; race; political ideology; cultural, religious or philosophical beliefs; sexual orientation; criminal history; health; disability; labor union membership status; genetics; biometrics; and others as specified by the law.
"Biometrics"	means	Personal Data resulting from the use of techniques or technologies related to the use of physical features or behaviors of an individual to enable the unique identification of the individual, e.g., facial recognition data, eye recognition data, or fingerprint data.
"Data Controller"	means	A person with the authority and duty to make decisions regarding the collection, use or disclosure of Personal Data.
"Data Processor"	means	a person who takes actions regarding the collection, use or disclosure of Personal Data under the instruction or on behalf of the Data Controller.
"Data processing"	means	any action that is performed on Personal Data or Personal Data sets, whether automatic or otherwise, e.g., collection, storage, system management, storage structure management, changes or alterations, acceptance, consideration, use, or disclosure by transmission or publication or other actions that lead to usage readiness, arrangement or combination, limitation, erasure or destruction of data.

3. What Personal Data does VAILOR CAPITAL collect, use and/or disclose?

3.1 Personal Data

Personal Data is data that can be used to identify a natural person, whether directly or indirectly, but which does not include data belonging to deceased persons. VAILOR CAPITAL may collect and gather the Personal Data of the Data Subject through several means, including the following:

Personal Data directly provided to VAILOR CAPITAL or through VAILOR CAPITAL or which exists with VAILOR CAPITAL, whether due to contacts, visits or searches via digital, website, call center, designated person or other channels.
Personal Data that VAILOR CAPITAL receives or has access to from other sources and not directly from the Data Subject, e.g., government agencies, other affiliated businesses/companies, financial institutes, agents, service providers, financial service providers, business partners, credit information companies and data service providers, etc. VAILOR CAPITAL will collect data from other sources only after receiving the consent of the Data Subject in accordance with the law, unless VAILOR CAPITAL has a necessity as legally permitted or as supported by law.

Below are some examples of Personal Data that VAILOR CAPITAL collects, uses and/or discloses:

Personal information such as first name, last name, nickname, personal identification number, passport number, position, signature, bank acount.
Contact information such as home address, workplace, telephone number, email and Line ID.
Information about devices or tools such as IP address, MAC address, and cookie IDs.
Other information such as usage activity of websites, audio files, still images, videos and other information received from the business operation of VAILOR CAPITAL.

3.2 Sensitive Personal Data

Sensitive Personal Data is Personal Data for which the law prescribes specific provisions. VAILOR CAPITAL has no intention of collecting any Sensitive Personal Data from you. However, in certain circumstances, VAILOR CAPITAL might be required to collect Sensitive Personal Data from you in order to prove and verify your identity or to accompany the participation of certain activities to you. Such data may include data on religious affiliation as stated in the copy of your citizen identification card, or race as stated in the copy of the passport of some countries and biometric data (such as facial recognition data, fingerprint data and electronic signature data in which technology is used to apply the unique signing behavior of the signature to verify and confirm the identity of the signatory), criminal background information, health information, disability information, sexual orientation, etc. Accordingly, VAILOR CAPITAL will collect, use and/or disclose such sensitive information only after VAILOR CAPITAL receives your explicit consent or in cases where VAILOR CAPITAL has a need to do so as permitted by law, in which case such actions may be carried out occasionally whenever there is a need to collect Sensitive Personal Data from you.

(Hereinafter in this policy, unless specifically mentioned, the above Personal Data and Sensitive Personal Data pertaining to the Data Subject will be collectively known as "Personal Data".)

4. For what purposes does VAILOR CAPITAL collect, use and/or disclose your Personal Data?

VAILOR CAPITAL will collect, use and/or disclose Personal Data for the benefit of the Data Subject in the participation of our activities or our business operation and in order to comply with any law which VAILOR CAPITAL or the Data Subject is required to follow and in order to undertake other activities as the law permits according to the purposes specified in this policy as follows:

4.1 For Participation in VAILOR CAPITAL's Activities

To enable the Data Subject to participate in VAILOR CAPITAL's activities as intended by the Data Subject who is party to a contract with VAILOR CAPITAL or in order to carry out a request of the Data Subject before attend the VAILOR CAPITAL's activities (contractual basis), for example:

In the consideration of approval for participation in current or future activities, seminars, or events organized by VAILOR CAPITAL.
In any activity related to carry out any actions related to investment, communication and coordination, due diligence, business review, or any business operations of us.

4.2 For Compliance with Relevant or Applicable Laws

For the purpose of compliance with the applicable laws (legal obligations), for example:

To comply with the instructions of a legally authorized party.
To comply with financial institute business laws, securities and exchange laws, cyber security laws, tax laws, anti-money laundering laws, anti-terrorism financing and proliferation of weapons of mass destructions laws, computer laws, bankruptcy laws and other laws which VAILOR CAPITAL is required to follow, whether in Thailand or abroad, along with announcements and regulations issued by virtue of such laws.

4.3 For Other Activities of VAILOR CAPITAL

CCTV footage and building access card exchanges.
For maintaining our relations, e.g., complaint management, satisfaction survey, attendee support, notifications any activities that the Data Subject is involved with VAILOR CAPITAL for the benefit of the Data Subject.
For managing risks, providing oversight, internal organization management and transmission to affiliated companies in order to achieve the aforementioned purposes.
For anonymizing Personal Data.
For preventing, handling or reducing risk of corruption, cyber threats, debt defaults or breaches of contract (e.g., bankruptcy information), and legal violations (e.g., money-laundering, terrorism financing and proliferation of weapons of mass destruction, offenses relating to property, life, body, freedoms or reputation), including the sharing of Personal Data in order to enhance the work standards of companies within the same business/company group for the prevention, handling and reduction of the aforementioned risks.
For the collection, use and/or disclosure of the personal information of directors, delegated persons and representatives of juristic person clients for the purpose of identity verification, authorization and receipt of authorization and/or for use as evidence to accompany related transactions and activities.
For making contacts, taking photos, making video and audio recordings relating to the organizations of meetings, lectures, recreational activities and exhibitions.
For the collection, use and/or disclosure of Personal Data of individuals in order to comply with related laws such as tax laws, anti-money laundering laws and bankruptcy laws, etc.
For sending and receiving packages, documents, or any communications.
For the analysis, development, and improvement of our various activities.

4.4 For Receiving Benefits from Participate in any Activities of VAILOR CAPITAL

For providing the Data Subject with better activities in accordance with the needs of the Data Subject.
For offering the special privileges, recommendations and various information, including rights to attend special activities.
In this regard, whether it is products and/or services, benefits, promotional offers, news or special activities of VAILOR CAPITAL or affiliated companies/businesses or any parties for which VAILOR CAPITAL acts as a representative, agent, distributor or VAILOR CAPITAL's business partner or third parties that are associated with VAILOR CAPITAL, whatever as permitted by the consent of the Data Subject.

If VAILOR CAPITAL needs to collect, use and/or disclose Personal Data from Data Subject for the purpose of entering into or complying with a contract between Data Subject and VAILOR CAPITAL and/or performing VAILOR CAPITAL's legal obligations, and the Data Subject fails to provide such required data to VAILOR CAPITAL upon request, VAILOR CAPITAL might not be able to proceed with your request, including the consideration, approval, or delivery of documents or information to the Data Subject, which may also affect the performance of duties under the relationship between the Data Subject and VAILOR CAPITAL.

5. Whose Personal Data might be disclosed by VAILOR CAPITAL?

VAILOR CAPITAL may disclose Personal Data to other parties with the consent of the Data Subject or rely on other legal basis as stipulated by the law to permit for such disclosures, whereby persons or agencies that receive such data will collect, use and/or disclose the Personal Data within the scope of consent granted by the Data Subject or within the relevant scope under this policy.

VAILOR CAPITAL may disclose Personal Data in order to accomplish various objectives, including to analyze and improve our business operation, to conduct research or prepare statistical data, to promote sales and to engage in VAILOR CAPITAL's public relations activities, including to facilitate business management, to prevent corruption and to allow other parties to provide supporting services to VAILOR CAPITAL in order to verify customer identity. In doing so, VAILOR CAPITAL might make disclosures to individuals or agencies such as affiliated businesses/companies, the Data Processor, business partners involved in the release of shared products (co-brands), third-party service providers, agents of VAILOR CAPITAL, sub-contractors, financial institutes, auditors, third-party auditors, rating agencies, asset management companies, credit rating agencies, legally authorized parties, parties interested in receiving the transfer of rights and/or recipients of rights transfers in transactions or business acquisitions of VAILOR CAPITAL, juristic persons or individuals that have a relationship or contract with VAILOR CAPITAL, including executives, employees, workers, sub-contractors, representatives and advisors of VAILOR CAPITAL and of such individuals or agencies that are recipients of the aforementioned data.

6. Does VAILOR CAPITAL transfer your Personal Data abroad?

VAILOR CAPITAL may need to transfer Personal Data to affiliated businesses/companies located abroad or to other data recipients as part of the normal business operations of VAILOR CAPITAL, such as when transferring Personal Data for storage on servers/cloud service providers in various countries.

If the destination country lacks adequate Personal Data protection measures, VAILOR CAPITAL will take care to ensure that the transfer of Personal Data takes place in accordance with the law and will take action to ensure the presence of Personal Data protection measures that are deemed to be necessary, appropriate and consistent such as by making confidentiality agreements with data recipients located in such country and/or making an agreement to ensure that your Personal Data will be protected under standards equivalent to the personal data protection standards of Thailand. Otherwise, in cases where the data recipient is an affiliated business/company within the same business network, VAILOR CAPITAL may adopt Binding Corporate Rules that is reviewed and approved by the relevant legal authorities and then transfer Personal Data to the affiliated business/company located abroad according to the aforementioned privacy policy in lieu of taking other actions as specified by the law.

International transfers of Personal Data must be strictly undertaken in accordance with Personal Data transfer policies.

7. For how long does VAILOR CAPITAL store your Personal Data?

VAILOR CAPITAL will store Personal Data for as long as required while the Data Subject is a client or has a relationship with VAILOR CAPITAL or for as long as required in order to achieve the related purposes set out in this policy. In doing so, it may be necessary to retain Personal Data after the termination of relationship with VAILOR CAPITAL until the statute of limitations has expired or for as long as prescribed or permissible by the law, for example:

For 5-10 years of storage according to anti-money laundering laws from the termination of the relationship, depending on the case;
For a period not exceeding 10 years of storage for verification purposes in cases where a dispute arises within the statute of limitations.

VAILOR CAPITAL will erase or destroy Personal Data or anonymize Personal Data only after the aforementioned necessity or duration has expired.

The storage, deletion and destruction of Personal Data will be undertaken strictly according to the Personal Data Storage and Destruction Policy.

8. How does VAILOR CAPITAL protect your Personal Data?

VAILOR CAPITAL will provide effective protection for your Personal Data through technical measures, organizational measures and physical safeguards to ensure appropriate security in the processing of Personal Data and to prevent Personal Data breaches. VAILOR CAPITAL has established policies, regulations and operational procedures for Personal Data protection, including information technology security standards and abuse of data prevention measures, and VAILOR CAPITAL regularly reviews and updates the aforementioned policies, regulations and procedures.

Furthermore, executives, employees, workers, contractors, representatives, advisors and data recipients of VAILOR CAPITAL are strictly obligated to maintain the confidentiality of Personal Data under the confidentiality measures established by VAILOR CAPITAL.

9. What are your rights regarding your Personal Data?

The rights of Data Subject under this clause are the legal rights that the Data Subject should be aware of. The Data Subject can exercise these various rights under the relevant law and policies enacted at the time or as amended in the future, including the criteria set forth by VAILOR CAPITAL, and in cases where the Data Subject is below 20 years of age or has limited legal capacity, the Data Subject may request to exercise their rights by assigning the Data Subject's parents, custody holder or authorized representative to state their intention.

Right to Withdraw Consent: If the Data Subject has given consent for VAILOR CAPITAL to collect, use and/or disclose Personal Data (whether the consent was given by the Data Subject before or after the effective date of Personal Data Protection laws), the Data Subject has the right to withdraw the consent at any time for as long as the Personal Data is held by VAILOR CAPITAL, unless it is subject to legal restrictions or contracts providing benefits to the Data Subject.
Accordingly, the withdrawal of the Data Subject's consent may impact to the participation to any activities. For example, the Data Subject may no longer receive new privileges, offers, information about other improved activities consistently according to needs or may not receive news and beneficial information, etc. Therefore, the Data Subject should review and inquire about the potential impacts before withdrawal of consent.
Right to Access Data: The Data Subject has the right to access their Personal Data that is under the responsibility of VAILOR CAPITAL and request copies of such data, including requesting VAILOR CAPITAL to disclose how VAILOR CAPITAL acquired the Data Subject's Personal Data.
Right to Data Portability: The Data Subject has the right to receive their Personal Data in cases where VAILOR CAPITAL has prepared such Personal Data in a structured format that can be read or used by an automated tool or device, and which can automatically use or disclose the Personal Data. This includes the right to request for VAILOR CAPITAL to transfer Personal Data in the aforementioned format to other Data Controller by automatic means and the right to directly receive Personal Data which VAILOR CAPITAL has transferred in the aforementioned format to other Data Controller, except for the cases where it is impossible to do so due to technical reasons.
Accordingly, the aforementioned Personal Data must be the Personal Data which the Data Subject has consented for VAILOR CAPITAL to collect, use and/or disclose or Personal Data which VAILOR CAPITAL must collect, use and/or disclose in order to enable the Data Subject to participate in VAILOR CAPITAL's activities as a contractual party or for the purpose of carrying out the requests of the Data Subject before participating in VAILOR CAPITAL's activities or be other Personal Data as determined by the legal authorities.
Right to Objection: The Data Subject has the right to object to the collection, use and/or disclosure of your Personal Data at any time if such actions are conducted for legitimate interests Personal Data of VAILOR CAPITAL or any third parties without exceeding reasonable expectations or for the purpose of fulfilling public interest missions.
If the Data Subject objects, VAILOR CAPITAL may continue to collect, use and/or disclose thier Personal Data solely for the parts in which VAILOR CAPITAL can demonstrate legal grounds that supersede even the fundamental rights of the Data Subject or for the establishment legal rights, compliance with laws, or defense of legal claims whatever the case may be.
Furthermore, the Data Subject also has the right to object to the collection, use and/or disclosure of thier Personal Data for the purposes related to direct marketing or conducting scientific, historical research or statistical studies.
Right to Erasure: The Data Subject has the right to request for the deletion or destruction of thier Personal Data or to anonymize Personal Data if the Data Subject believes that their Personal Data are collected, used and/or disclosed in violation of related laws or if VAILOR CAPITAL no longer needs to retain such Personal Data according to the related purposes described in this policy or when Data Subject has exercised the aforementioned Right to Withdraw Consent or the Right to Objection.
Right to Restrictiona: The Data Subject has the right to temporarily suspend the use of Personal Data in cases where VAILOR CAPITAL is undergoing a review pursuant to the request to correct or objections or in other cases in which VAILOR CAPITAL no longer needsto delete or destroy the Personal Data but the Data Subject requests to suspend the use of data instead of deletion or destruction.
Right to Rectification: The Data Subject has the right to request correction of their Personal Data to ensure it is accurate, up to date, complete and not causing misunderstandings.
Right to lodge complaints: The Data Subject has the right to file complaints to the relevant legal authorities if the Data Subject believes that the collection, use and/or disclosure of their Personal Data is in violation or in breach of applicable laws.
The exercising of the Data Subject's rights above may be subjected to limitations pursuant to related laws and there may be certain situations and necessities in which VAILOR CAPITAL may refuse or be unable carry out Data Subject's requests to exercise the aforementioned rights such as legal obligations or court order compliance, public interest, or to protect the rights and freedoms of others, etc.
If VAILOR CAPITAL refuses such requests, VAILOR CAPITAL will inform the reason of the refusal to the Data Subject, and the Data Subject can exercise their rights through the contact channels stated in this policy.

10 Will VAILOR CAPITAL Amend, Update or Revise this Policy?

VAILOR CAPITAL may consider making changes, additions, updates or revisions to this policy from time to time as appropriate and as permissible by law. In the event of any changes, additions, updates or revisions to this policy, VAILOR CAPITAL will announce the latest version of the policy for your information via www.vailorcapital.tech/privacypolicy

11 How can you contact VAILOR CAPITAL and the Personal Data protection officer?

If the Data Subject has any suggestions or inquiries regarding the collection, use and/or disclosure of their Personal Data, including requests to exercise their rights under this policy, the Data Subject can contact VAILOR CAPITAL and/or the Data Protection Officer via the following channels:

VAILOR CAPITAL Website: www.vailorcapital.tech
Data Protection Officer’s email: KX_DPO@kbtg.tech
Address: Kasikorn X Venture Capital Co., Ltd.: No. 46/6, Popular Road, Ban Mai Sub-district, Pak Kret Sub-district, Pak Kret District, Nonthaburi Province 11120.