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Pay Speed PLC Privacy Policy

1.Personal Data Confidentiality

1.1.Pay Speed PLC (hereinafter referred to as the ‘Pay Speed’) strive to protect the confidentiality of the personal information (‘Data’) of customers, employees and business counterparts (hereinafter collectively referred to as ‘Data Subjects’), that has been provided to the Pay Speed. This Policy is accordingly addressed to these Data Subjects in the jurisdiction of the Kingdom of Cambodia.

1.2.This Policy is developed to assist you, as a Data Subject, in understanding how we collect, disclose, transfer and store your personal information and how we intend to deliver the rights and protection that you are entitled to.

1.3.Ensuring the security of your personal information is our priority. We strive to protect the confidentiality of this information by maintaining appropriate physical, electronic and procedural safeguards. We invest in systems and infrastructure to minimize any risks of compromising data security. Each of our employees is also bound by our Employee Code of Conduct which requires them to maintain customer confidentiality at the utmost priority.

1.4.When we use other companies to provide services to our customers on our behalf (hereinafter referred to as the ‘Service Providers’), we also require them to protect the confidentiality of your personal information that they may receive.

1.5.In relation to Clause 1.4 above and Clause 4.2 below, please understand that we will only share your information with our Service Providers and business partners in accordance with this Policy.

2.Choice to Supply Personal Data

2.1.As a Data Subject, you are provided opportunities to make choices. We encourage you to make choices that enable us to provide you with quality products and services that help you to meet your financial needs and objectives.

2.2.The collection of data by the Pay Speed may be mandatory or voluntary/optional in nature in order to establish or continue to enjoy the Pay Speed’s financial services and/or establish any other business relationships with the Pay Speed.

2.3.It is necessary for you to provide data which are mandatory. If you choose not to supply such data, this may result in the Pay Speed being unable to provide products and/or services or otherwise deal with you.

2.4.We strive to keep you informed on the latest marketing and promotional offers that might be important and beneficial to you. These may include programs you may find valuable in helping you to maximize the experience of using our products and services.

2.5.However, you can choose not to receive these marketing and promotional offers. You can do so by informing the Pay Speed through e-mail or a direct call to our customer service team.

3.Types of Personal Data Collected

3.1.Personal data is described as information relating directly or indirectly to an individual who is identified or can be identified from that information.

3.2.The types of personal data collected may vary according to the business relationship that is established. Data collected may include the following:

Data collected on mobile applications or other forms or as provided by you, such as name, identity card number or passport number (for foreigners), address, e-mail address, telephone number, occupation, financial position such as assets and income, personal information and such other information as may be relevant for your application;

Data about your transactions with the Pay Speed, its Service Providers, business partners or third parties, such as wallet balances, payment history and wallet activity;

Data from credit bureau reports;

Data from credit reporting agencies;

Data from governmental agencies, regulatory and statutory authorities;

Data obtained from your access to the Pay Speed’s web server, for example, by the use of cookies, i.e. small text files, sent by the Pay Speed’s server to your system when you access the Pay Speed’s server;

Data for insurance products; and

Data from publicly available sources.

4.Use of Personal Data

4.1.The Pay Speed collects your data for the provision of financial services or products requested by you in order to meet your financial needs and objectives.

4.2.In addition to the above, the Pay Speed may also make arrangements with business partners to jointly develop products and services or launch marketing campaigns that may involve the sharing of your personal information.

4.3.Your personal data may be used or processed by the Pay Speed or the Pay Speed’s Service Providers for the following purposes:-

To establish a relationship between you and the Pay Speed and/or companies related to or affiliated to the Pay Speed, the Pay Speed’s Service Providers and business partners;

To process applications for products and services;

To evaluate and monitor fraud and suspicious transactions;

For evaluation and due diligence purposes;

For the provision of products and services to you, whether through face-to-face interaction or through electronic means, including processing of fund transfers and payments, mobile phone top-ups, bill payments etc.

For data processing purposes;

To evaluate and monitor provision of services;

To respond to inquiries from you;

To understand your needs and offering products and services to meet those needs;

For the research and development of products and services for customers’ use;

To allow the Pay Speed, the Pay Speed’s related and/or affiliated companies, Service Providers and business partners to promote their products and services;

For enforcement of our rights and obligations of other parties to us and/or our affiliates;

To enable a party to evaluate any actual or proposed assignment, participation, sub- participation and/or novation of our rights and/or obligations;

To meet legal and regulatory requirements, which may include disclosure, notification and record retention requirements;

To maintain and protect our offices and automatic teller machines;

For audit and risk management;

For any transfer or proposed transfer of any part of the Pay Speed’s interests, obligations, business and/or operations;

For such other purposes as permitted by applicable law or with your consent; and

For all other purposes incidental and associated with any of the above.

5.Disclosure of Personal Data

5.1.For the purposes above, your personal data may be provided by the Pay Speed to:-

Any person under a duty of confidentiality to the Pay Speed or to companies related to or affiliated to the Pay Speed;

Companies related to or affiliated to the Pay Speed (whether such company operates in Cambodia or elsewhere);

Any financial institution granting or intending to grant any credit/financing facilities to you, the Credit Bureau of Cambodia, any other relevant authority as may be authorized by law to obtain such information, authorities/agencies established by the National Bank of Cambodia and/or any other person as may be authorized by law or any government authority and/or regulatory authority and/or any industry related association;

Any relevant agent, contractor or third party Service Provider who provides administrative, telecommunications, computer, payment, securities clearing, management, audit or other services to the Pay Speed;

Any banking, financial or other institution with which you have or propose to have dealings with;

Any credit reference agency or debt collection agencies;

Lawyers, auditors, tax advisors, investment banks and other professional advisors which is restricted to the nature of the business relationship in which you are involved in with Pay Speed PLC;

Any insurance company operators and any association or federation of insurance companies operators;

Any person or corporation to whom the Pay Speed transfers or proposes to transfer any part of its interests, obligations, business and/or operations;

Any nominee, trustee, co-trustee, centralized securities depository or registrar, custodian, estate agent, solicitor or other person who is involved with the provision of services or products by the Pay Speed to you;

Any person by whom the Pay Speed is required by applicable legal, governmental or regulatory requirements to make disclosure; or to any other person reasonably requiring the same in order for the Pay Speed to carry out the activities set out in the above purposes.

6.Right to Access and Correct Personal Data

6.1.You are entitled to ask whether the Pay Speed holds data on you and to request access to and the correction of any such data held. You will be required to fill up a form and a reasonable administrative fee may be charged for processing each data access request.

6.2.If you wish to make any request for access to, or to correct data held by the Pay Speed, please forward your request to the Pay Speed’s Customer Service Team via e-mail at info@speedpayplc.com or call us at the telephone number currently stated at the Pay Speed’s website (www.speedpayplc.com) and we will facilitate the fulfillment of your request as soon as possible.

7.Amendments to Privacy Policy

7.1.This Policy may be reviewed and amended from time to time. We will communicate such changes along with the updated Policy on the Pay Speed’s website (www.payspeed.com), and/or other appropriate communication means as may be determined by the Pay Speed.