Maikeru Asset Management

Privacy Notice

Introduction

Definitions

“You” Client
“We”, “Our” and “Us” Maikeru Asset Management Company Limited
“Customers” Customers, business partners and all parties who have dealings with us

“Personal Information”

The same definition as “personal data” is defined in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which refers to any data belonging to a person that permits that person’s identity, whether directly or indirectly, but expressly omitting data of the deceased.

“Sensitive Personal Information”

The same meaning as “sensitive personal data” prescribed in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which refers to personal data relating to a person’s race, ethnicity, political opinion, cult, religious or philosophical beliefs, sexual behaviour, criminal records, health, disability, labour union, genetics, biometrics, or any data which may affect the data subject in the same way as prescribed by the Regulator.

“Use”, “Process”

The same meaning as “processing” as defined in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), which includes, among other things, collecting, processing, retaining, disclosing, and so on.

General

Maikeru Asset Management Company Limited is dedicated to safeguarding any personal information provided to us. Privacy is important to us, and we will only collect and use personally identifiable information if it is both necessary and lawful.

Maikeru Asset Management Company Limited has prepared this Privacy Notice to inform you about the types of personal information we collect; what we do with that information; who we may share it with and why; and your choices and rights regarding your personal information.

We may need to amend our Privacy Notice from time to time, so please monitor our website for updates. If we make significant changes to how we handle your personal information, we may contact you to notify you.

Maikeru Asset Management Company Limited is a global asset management company. We invest and manage assets for institutional investors and private clients, and we provide investment strategies and solutions to our clients.

Personal information we collect and use

We may collect and use personal information including:

  • For identification and security purposes, information about who you are, such as your Full Name, Date of Birth, Gender, Marital Status, Country of Birth, National Identification Card Number, Nationality, Passport Number, Expiry Date and Place of Issuance, Occupation and employment details, including job title, salary, and employer’s address;
  • Information that will allow us to contact you, such as your address (current address in Thailand and Registered home address if different), Phone number (mobile), and email address;
  • Information connected with your product or service with us, e.g. bank account and sort code
  • Information about your contact with us e.g. phone calls, emails/letters;
  • Information that is automatically connected e.g. via cookies when you visit one of our websites;
  • The information is described as ‘sensitive personal information i.e. information pertaining to your race, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behaviour, criminal records, health, disability, trade union information, genetic data, biometric data, or of any data which may affect you in the same manner, as prescribed in Thailand’s Personal Data Protection Act B.E. 2562 (2019) (“PDPA”). Such sensitive personal information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information;
  • Information on persons connected to you, where required to provide the agreed product or service e.g. name, date of birth, nationality, National ID number or Passport Number of your spouse or beneficial owner.

If you have a distributor/broker/agent, the information we gather and utilize was most likely submitted on your behalf by them.

    Why collect and use your personal information

    We value your privacy and will only collect and use your information when it is both necessary and legal. We will only collect and use your information if we can meet one of the data protection laws’ legitimate processing criteria. These include:

    • Where necessary to offer the product or service you have requested, for example, if you want to invest in one of our funds or products, we will need certain personal information from you, such as your name, address, date of birth, and bank account information;
    • Where information is essential for us to satisfy our legal or regulatory requirements, such as sending you Annual Statements, informing you of changes to our Terms and Conditions, or detecting and preventing fraud;
    • For our legitimate interests when they do not outweigh yours as the data subject, such as developing new goods and services for our customers;
    • For the completion of duty that we are required to complete in the public interest;
    • You have given us express permission to use your personal information for the agreed-upon purpose. For example, if we are moving your personal information outside of Thailand for processing purposes, if we are collecting and utilizing sensitive personal information, or if we are doing certain sorts of marketing and research, and/or call handling. You can opt-out of such activities by contacting us using the details provided below.

    Subject to the restrictions set out above, we may use your personal information for the following purposes:

    • Account opening including information verification and credit checks
    • Order Handling
    • Unit Allocation
    • Regulatory and Compliance Reporting
    • Service Request (Amendment, Online trading, Withdraw, Redemption, Closure and Tax Certificate)
    • Payment Application
    • Dividends Confirmation
    • Marketing and Research, including analysis and promotion with your explicit consent
    • Call Handling (Incoming and outgoing) – with your explicit consent.

    As indicated above, you will be asked to give the personal information necessary to be processed by or on behalf of us. If you do not agree to disclose such personal information to us by this Notice, we may be unable to supply you with the requested product(s) or service(s) or meet any of our contractual responsibilities to customers.

      Proper Management and Protection of Personal Information 

      We take personal information and security extremely seriously, and we endeavour to always meet our duties. Any personal information collected and used by us in any way will be subject to adequate safeguards to ensure the management and protection of your personal information. We have put in place the following measures:

      • We have established an organizational culture that promotes and ensures the security of any personal information that we hold;
      • Personal information controllers have been appointed to supervise the appropriate management of your personal information;
      • To guarantee the correct treatment of personal information, internal firm policies based on Personal Information Protection Laws and instructions published by the competent government were formed;
      • We have educated our workers to guarantee that they appreciate the importance of personal information security and are well-versed in all relevant regulations and guidelines;
      • Developed a personal information management registry and enforced appropriate access controls to personal information;
      • Established suitable and reasonable security measures [such as a secure storage mechanism with restricted access restrictions] to prevent unauthorized access to, or leakage, destruction, or modification of, personal information. Our security measures are by industry standards and best practices, and they provide an acceptable control environment for managing threats to the confidentiality, integrity, and availability of your personal information.

      Disclosure of Personal Information to Third Parties  

      We may share your personal information with third parties with whom we collaborate for the objectives stated in the section under “Why we gather and use your information.”

      We will only release your Personal Information to such third parties if it is legal and in accordance with our duties under data protection legislation.

      We will share your information with the following parties:

      • Other components [subsidiaries, holding companies, linked organizations, or future affiliates of ours] who assist us in providing the product or service you have;
      • Companies and partners, both inside and outside of Thailand, that we have carefully selected to help us;
      • Credit reference companies are used to conduct credit checks and ID verification.
      • Where this is necessary as part of the product or service you have agreed upon with us, your distributor/broker/agent;
      • Our Thai regulators include the Securities and Exchange Commission (SEC) in Thailand.
      • Appointed agency [government agencies, public agencies, agencies] in charge of monitoring service delivery;
      • Law enforcement agencies, for example, for crime prevention and detection, as well as the pursuit of legal actions; and
      • Other third parties may be necessary to assist in the reorganization, amalgamation, merger, or sale of an organization.

      By sharing your personal information with such third parties, we assure you that those individuals will keep your information secret and will not use it for reasons other than those mentioned by us.

      We will only authorize a third party to process your personal information on our behalf after obtaining the appropriate assurance that they will manage and secure your information by relevant laws. Furthermore, before we provide and disclose your personal information to such service providers, we require assurance that they will process this data strictly by our instructions and agreed-upon terms of use, including appropriate measures to properly handle personal information, via a written contract or similar means. We audit their continued compliance with these requirements on a regular basis.

      How long we keep your information

      We maintain your personal information and copies of records we make (e.g., conversations with us) while you are a client or customer of ours to offer your product or investment and satisfy our legal and regulatory requirements.

      Even if you no longer have a connection with us, we must retain information for a variety of legal and regulatory reasons. The amount of time will vary, and we will assess our retention periods on a regular basis to ensure that they comply with all laws and regulations.

      Personal data must be destroyed or anonymized at the end of the appropriate retention term. If data cannot be assigned to an identifiable individual at the end of the retention term, no action is necessary for some situations.

      Your rights under law

      Under data protection legislation, you have several rights that you can use in specific circumstances.

      These are:

      1. Right to be Informed
      2. Right to Withdraw Consent
      3. Right of Access
      4. Right to Receive and Transfer
      5. Right to Object
      6. Right to Erasure and Destroy
        -Your personal information is no longer required for the reasons for which it was collected, utilized, or disseminated;
        -You revoke the permission that is the basis for the collection, use, or disclosure, and there is no legal basis for such collection; and
        -You are opposed to the collection, use, or disclosure of Personal Data as defined in Section 32 of the Personal Data Protection Act.
      7. Right to Restrict

      If you want to exercise any of your legal rights, please contact us and ask for the Data Subject Rights Request form. Instead, you can tell us of any changes using the information provided below.

      How to contact us 

      Please contact us if you have any questions regarding our Privacy Notice or the information we collect or use about you:

      Thailand Data Protection Officer
      Maikeru Asset Management Company Limited
      Level 18, Park Ventures Ecoplex, 57 Witthayu Rd, Lumphini, Pathum Wan District, Bangkok 10330, Thailand
      Email: contact@maikeru-assetmanagement.com

      How to make a complaint 

      Your personal information will always be collected, used and safeguarded by data protection laws. If you feel we have not treated your information by this Privacy Notice, please notify us immediately, and we will do everything possible to put things right.

      While we try to address any issues for you, you have the option of contacting your local data protection authorities, such as the SEC in Thailand. Whether you have exhausted our complaint system, you have access to this.

      You can contact the Office of the Personal Data Protection Committee at the following address:

      Office of the Personal Data Protection Committee, Office of the Permanent Secretary
      Ministry of Digital Economy and Society
      5th December, B.E.2550
      120 Moo 3 Bldg. B, 6-9 Floor
      Chaengwattana Road
      Laksi, Bangkok 10210

      E-mail: pdpc@mdes.go.th
      Tel: +66 2 142 1033

      The performance comparison relating and past performance to a capital market product is not a guarantee of future results. The investors may request the prospectus from Maikeru Asset Management Company Limited or distributors for additional fund information. An investment in a fund is subject to currency risk and may deliver a lower return than the initial investment. The investment manager hedges currency at his or her discretion. Before making an investment decision, consider the product's features, conditions, and relevant risks. It is advisable for investors to review the prospectus of the fund to determine if there are any tax benefits.

      There's a high level of risk or complexity involved with investing in a Maikeru Asset Management Investment Fund, which is different from investing in a general fund. Regardless of previous investment experience or previous transactions in a capital market product, the investor should understand the risks and specific conditions of these funds and seek additional advice from distributors and/or management company before making a decision to invest.

      The website provides information on Thailand-domiciled unit trust schemes managed by Maikeru Asset Management Company Limited. The information and products contained on this website are for investors both within and outside of Thailand. This website is subject to important legal and regulatory restrictions. This information is outlined in the Disclaimer section, which you should read before proceeding. By proceeding, you represent that you understand these restrictions.

      The information on this website does not constitute an offer to buy securities, or an invitation to buy securities in any jurisdiction where such an offer or invitation is unlawful, or where the person making the offer is not qualified to do so.

      We are not responsible for the content of any external websites.