Privacy Policy Notice
Talis Asset Management Co., Ltd. (“TALIS”) upholds the importance of privacy and therefore emphasizes personal data protection for our clients as we strive to offer the best services to you. We would like to take this opportunity to describe our data privacy policy which outlines how we collect, use, and disclose data of persons who use our services and/or products through our various channels.
Visiting our website
Clients are welcomed to use our website to obtain information about our fund products and various services, or find out more information about the company. You need not reveal any personal data to TALIS to visit the website, if you do not wish to subscribe and receive news updates from us.
TALIS regularly updates and refreshes its website and may use software to help describe how visitors use our website in order to enable us to better tailor the website to suit our intended clients. Data collected include statistics such as the time of visit and duration, which pages were viewed and for how long, the internet provider, and what other websites were viewed before and after visiting our website.
TALIS may observe how existing account holders tend to use and browse through information and links on our website, as well as which services they use. As part of our data protection policy, TALIS may use cookies for tracking purposes, which involves cookies being sent from our website to the user’s computer and remains active while the viewer is using the website. Note that cookies are configured by us and are no longer active after tracking implemented by TALIS is finished; see TALIS’s Cookies Policy.
Persons whose data the company collects, uses and discloses, include the following data subjects:
- Retail clients
- Institutional clients: directors, shareholders, ultimate beneficiaries, employees, legal representatives of the institution
- Persons who are not clients: potential investors or users of the company’s services; subscribers to the company’s newsletters; visitors to the company’s website; ultimate beneficiaries; directors, shareholders, employees, legal representatives of juristic persons with business activities with the company or our clients or our counterparties; directors, shareholders, advisors, and employees of the company.
Personal data collected, used, and disclosed
TALIS collects, uses, and discloses your personal data which are obtained directly from you, or exist with TALIS either through using our products or services, contacting, visiting, searching through digital channels, website, call center or from other sources such as from representatives, fund selling agents and distributors, independent investment advisors, social networks, government authorities (i.e. Business Development Department, Securities and Exchange Commission, Anti-Money Laundering Office, Legal Execution Department, Revenue Department etc.), and other public information sources, etc. TALIS will collect information from other sources with the consent of the data subject, unless TALIS has a necessity as permitted by law. Only data necessary or relevant to contractual obligations and/or to obtain services from TALIS are used to achieve the intended purposes which the client is already aware of, and will be kept in the form of documents, files, reports, diagrams, maps, drawings, photos, image recordings, video recordings or sound recordings by electronic instruments, or any other ways that the recordings may have information which may reveal the person’s identity.
Personal data refers to information about the client which may reveal the person's identity. However, this excludes specific data on deceased individuals.
The company may collect Sensitive Personal Data such as religion, blood type, and/or race, which appears on the photocopy of your ID or that you have provided information to the company, biodata (i.e. face recognition and voice recognition data), medical and disability data, criminal records, all of which helps verify your identity for the Know-Your-Customer process and whenever your identity needs to be confirmed. Use of sensitive personal data is enabled if the company receives consent from the client that voluntarily discloses the data or documents containing such information, or if the law permits such data collection. However, only data that are necessary for the intended purposes will be collected.
TALIS collects your personal data when you apply and/or enter a contract to use our services and/or products as follows:
- Personal details and contact information such as your name, surname, ID card number, passport number, address, telephone number, date of birth, sex, e-mail, photo, profession, work place, marital status, spouse's's details, nationality, beneficiary's details, signature, child information, copy of ID/passport, expiration date etc.
- Court and legal records, or personal information that must be disclosed by law governing the company's business operations such as history of breaching money laundering laws.
- Financial records such as your bank account information, income level, source of income, tax records, credit history, etc.
- Data about fund products you invest in and services you use, including various transactions and activities you have with the company such as orders to buy/sell units of funds under management, investment transactions of funds, funds’ performances, payment records, etc.
- Status with regards to laws on money laundering and financing of terrorism, bankruptcy laws, US laws to curb tax evasion by individuals and companies conducting cross-border transactions (Foreign Account Tax Compliance Act or FATCA), and Common Reporting Standard (CRS)
- Data regarding usage of our website and other websites or applications which access our products and services.
- Your contact history with the company such as audio recordings of conversations, telephone numbers, complaints, and saved data, collected when you contact our staff or use our various channels.
- Data you submit to the company in order to access our services or participate in any company activities such as topics of interests, preferences, etc.
- Personal data which the law requires the company to collect, use, and disclose which are obtained when you contact or apply to use our products and/or enter a contract agreement with the company.
- Any other personal data which the law requires that consent is obtained from you before being collected. The company will inform you and seek your consent before collecting such data or within the schedule prescribed by law.
If you do not reveal certain personal data or do not provide consent and/or withdraw your consent to allow us to collect, use, and/or reveal data, this may prevent the company from processing your request or servicing you.
When you submit personal data of a third party to the company (a third party includes, but is not limited to, family members or ultimate beneficiaries of the investment), you must endorse and guarantee the accuracy of the information on that third party, and confirm that you have already fully notified the third party about details of this privacy notice and have already obtained consent from that third party.
Purpose for collection, usage, and disclosure of personal data (Personal Data Processing)
TALIS is required to process your personal data according to stated purposes, such as:
- Perform tasks according to contract or agreement made between the company and the data subject. The client or investor must submit personal data to verify one's identity to the company to enable the company use that data to provide services, open a fund account or private fund management contract, carry out tasks requested by the user, perform the tasks required by the contract, handle all tasks related to the product and/or service, contact the investor, notify about changes to products and services, issue reports as required by law, including any other tasks whereby omission would constrain TALIS's ability to handle or provide services, confirm identity before processing a transaction, handle a task requested by you, or handle any complaints raised by you.
- Comply with laws and regulations. The company may use personal data of the client or investor for data processing that is required by applicable laws and regulations. This includes tasks requested by court orders, regulatory agencies and authorities such as the Securities and Exchange Commission, Bank of Thailand, Anti-Money Laundering Office, Revenue Department, Legal Execution Department, and Stock Exchange of Thailand, Office of the National Anti-Corruption Commission, etc.
- For legitimate benefits. The company may use personal data of the client or investor to support internal management and reporting tasks within the company and support business operations such strengthening risk management, system and network security, CCTV recording, supervision, new product development, analysis and inspection of corruption or money-laundering activities, customer satisfaction assessment, complaint handling, conference/seminar attendance, customer feedback, etc.
- Handle tasks according to consent provided by the data subject. The company may use personal data of the client or investor to distribute news and offer our products and/or services or analyze your sensitive personal data such as race, religion, and blood type appearing on the photocopy of your identification document (i.e. ID card, passport, any other identification document issued by a government authority), data on health or impaired hearing/vision, data on deficiencies in communication and decision-making, which helps us properly customize sales processes and services that are appropriate for you. If the client or investor does not provide consent to allow the processing of aforementioned personal data, this may constrain the scope of services the company can handle and may prevent the company from carrying out the tasks you requested or from providing services to you.
If the client or investor is required by law or contract to submit such personal data, or required to submit to enter a new contract agreement or any other reason, failure to submit such data may prevent other related transactions and tasks associated with that client or investor to be blocked or suspended until the company receives the client or investor’s personal data. This is due to the fact that the company will not be permitted to use such personal data or the law states that the transaction or task must not be processed, etc.
Storage and maintenance of personal data of the client or investor
- TALIS only maintains your personal data that is essential to data processing needs, including complying with the applicable regulatory requirements. Personal data is stored as documents and/or electronic files, for the entire duration of your business relationship with the company as well as the period required by law such as having to preserve the client's personal data for at least 10 years following termination of account relationship with the client as prescribed by anti-money laundering laws or as records needed for a Revenue Department audit, etc.
- The period can also be dependent on the duration of any legal case. TALIS will keep your personal data in the appropriate form in accordance to the type of personal data maintained. However, it is also necessary for the company to keep your personal data after a legal case has been settled in order to comply with other relevant laws that apply.
- If the law does not explicitly state the time period to maintain such personal data, TALIS will determine the period based on the length of time necessary for the company's operations and to allow the company to service the client according to the consent received. The company will take appropriate steps to delete or destroy or remove your identity from such data once the data preservation period has ended, or once the company receives a request to delete or destroy or a notice to withdraw consent to use your personal data, as applicable.
Usage and disclosure of personal data of the client or investor
Once the individual has given consent, or if use of personal data is necessary to carry out contractual obligations or comply with the law or for any other legitimate reasons, TALIS may submit, transfer, use and/or disclose an individual’s personal data to a third party domiciled either domestically or in a foreign country. TALIS may disclose or use an individual’s personal data in accordance with the aforementioned purposes with third parties such as:
- Business partners, including directors, staff, subcontractors or representatives of those companies such as fund selling agents and distributors, independent investment advisors and private fund marketing representatives. ;
- Regulatory agencies that supervises asset management companies or other authorities empowered to instruct TALIS to submit personal data or assets of individuals, such as the Securities and Exchange Commission, the Anti-Money Laundering Office, Stock Exchange of Thailand, Legal Execution Department, Revenue Department, etc.
- Court of law, police, and other authorities empowered by the law to publicly inspect, prosecute, and press charges.
- Agencies, organizations, third parties, and any other juristic person with a contract agreement or business relationship with TALIS whereby we will need to reveal an individual's personal data in order to process the services required by the contract, to comply with the law or to perform the contract. Examples include the registrar, trustee, brokers, fund administration service providers, data storage service providers, Thailand Securities Depository Company Limited, SET Trade Dot Com Company Limited, Digital Access Platform Company Limited, auditors, sending buy/sell orders of local and foreign securities for private funds, banks, etc.
- The Company does not provide information to third parties for marketing purposes.
International transfer of personal data (if any)
It may be necessary for TALIS to disclose or forward your personal data to a foreign party or international organization that has adequate personal data protection measures, or the company may need to keep personal data on servers located outside Thailand, or if necessary to comply with the law. If there is a need for TALIS to disclose or forward your personal data to a foreign party or international organization that has lower data protection measures than Thailand's standards, TALIS will take appropriate steps such as at least imposing data confidentiality measures by establishing a data confidentiality agreement, etc.
The individual’s rights to one’s personal data
Personal data protection law stipulates that the individual possess certain rights regarding one’s own personal data that is collected and used by the company.
- Right to access and obtain a copy of one's personal data, including the right to request the company to reveal how any unauthorized personal data was collected without the individual's consent.
- For data which the company has already transformed into automated machine-readable format or allow disclosure through machine readable methods, the data owner has the right to request to obtain or transfer one's personal data to another automated data controller. This excludes cases where it is technically not possible, or involves transfer of personal data which the company must use to perform a public task or to comply with the law, or would violate the rights and freedom of other individuals.
- Right to object to the collection, usage, or disclosure of one's personal data, such as applying one's personal data for marketing purposes.
- Right to delete or destroy or remove one's identity from personal data.
- Right to request temporary suspension of the use of one's personal data.
- Right to request the amendment of one's personal data.
- Right to revoke permission previously given to the company to collect, use, and/or disclose one's personal data that required consent.
The rights of the data owner depend on other associated factors. Any request to exercise of your rights as mentioned above must be done in writing. TALIS will comply with the legal requirements related to your rights as a personal data subject. TALIS reserves the rights to reject certain requests according to terms stated by the law. If TALIS is unable to process your request, we will make a record of the rejected task and the reasoning. If you request to delete or remove your identity from your personal data or to withdraw a previously given consent to use your personal data, this can affect our ability to perform our contractual obligations and provide other services due to absence of personal data about you. The company will not be able to provide some services which needs to use such information.
TALIS may apply charges as appropriate to cover the expense of processing the aforementioned requests. The company will finish processing your request within 30 (thirty) days after your request is received by the company.
Data Security
TALIS adopts strict security measures governing internal operations and enforcement of the Privacy Policy to ensure your personal data is protected, such as extensive use of password protection and access controls. The company requires that its staff and outsourced vendors comply with these measures and the Privacy Policy, including the requirement that appropriate protection and procedures are established to govern the use, movement, and transfer of personal data.
Marketing and sales promotion information
The company may distribute marketing materials and information concerning sales promotions, products, research analysis, and fund services to the client or investor which the company determines may be of interest or beneficial to the client or investor. If the client or investor do not wish to receive such news notifications, you may cancel the process on our website www.talisam.co.th/subscribe or "Subscribe" and click Unsubscribe.
Maintenance and usage of personal data previously acquired
The company has the right to continue to maintain and use your personal data which the company had previously collected for the original intended purposes prior to the proclamation of the Personal Data Protection Act with regards to personal data collection, usage and disclosure. If you do not wish the company to continue to maintain and use the aforementioned data anymore, you may notify the company to withdraw your consent in accordance with your rights as the data subject. However, disclosure or any other processing that is not considered maintenance and use of your personal data shall be governed by the company’s Privacy Policy.
Revisions to the Privacy Policy
TALIS will review the Privacy Policy covering personal data regularly to ensure compliance with applicable laws and regulations on personal data protection. When there are revisions to the Privacy Policy, we will post updates on the company’s website promptly.
Contact us
Details of personal data controller
Name: Talis Asset Management Co., Ltd.
Address: AIA Capital Center, 10th Floor 89 Ratchadapisek Road Dindaeng, Ratchadapisek, Dindaeng,
Bangkok 10400 Telephone: 020150222 Press 0
To make any of the aforementioned requests permitted by law, or to inquire further about personal data collection, usage and disclosure, please contact TALIS (Data Protection Officer) at:
- Website / Contact Us: www.talisam.co.th/contact-us/ and select “DPO Office”
- Telephone: 020150222 press 0
- Postal mail: Talis Asset Management Company Limited, AIA Capital Center, 89 10th Fl., Room 1001-1002, Ratchadapisek Road, Dindaeng, Bangkok 10400. Attn: “Personal Data Protection Officer”
- Email: dpo-office@talisam.co.th