PRIVACY POLICY

Wing Bank (Cambodia) Plc. (“Wing Bank”, “we”, “us” “our” or “Data Processor”) understands that your privacy is very important to us. We respect your privacy and commit to protecting it through our compliance with this Privacy Policy and applicable Cambodian laws.

This Privacy Policy aims at providing you with the knowledge on how Wing Bank collects and manages your Data as you interact with Wing Bank, although through direct or indirect channel. You acknowledge that you have read this Privacy Policy prior to interacting with Wing Bank for any matter. In this context, “Data” refers to any information as mentioned in part 3 of this Privacy Policy including your personal data.

Your access and continue interacting with Wing Bank either directly or through any of our platforms including website, mobile application, and other applicable platforms (“Wing Platform(s)”), deems acknowledgement and acceptance of this Privacy Policy.

By interacting with us, submitting information to us, or (for our employees) by your continued employment with us, you agree and consent to Wing Bank (including related corporations and business units under Royal Group), as well as our agents collecting, using, disclosing and sharing amongst ourselves your Data, and disclosing such Data to our authorized service providers and relevant third parties in the manner set forth in this Privacy Policy.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about any changes and such changes will be reflected in this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Wing Platform and other applicable channels, and you hereby waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Wing Platform or any product /service provided by Wing Bank after the date such revised Privacy Policy is posted.

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

We collect your Personal Data, including your name, ID/passport number, billing address, shipping address, payment information, email address, phone number and other information (depending on the nature of your interaction with us) that you voluntarily give to us when you register and/or access to Wing Platform or when you choose to participate in various activities related to or under Wing Platform or when you subscribe to any product/services provided by Wing Bank.

Information from third parties, such as personal information or network friends, if you connect your account to the third party’s platform and grant the Wing Platform permission to access this information.

When you visit the Wing Platform, our system will automatically collect certain data/information about your device, including but not limited to information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.

Additionally, as you browse Wing Platform, we collect information about the individual web pages or any items or feature that you view or use, what websites or search terms referred you to the Wing Platform, and information about how you interact with the Wing Platform.

Financial information, such as data/information related to your payment method (e.g. valid credit/debit card number, card brand, expiration date) that we may collect when you make transaction, purchase, order, return, exchange, or request information about our services from the Wing Platform.

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including but not limited to your mobile device’s bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, call log information (including incoming and outgoing call and your call duration), installed application (including traveling, utility, governance, banking, entertainment applications and others) and other features available in your mobile device. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

This Privacy Policy applies to Data we collect from you when you interact with Wing Bank, directly or indirectly, through the following channels or other channels as may be applicable from time to time:
• Wing Platform: We collect information when you retrieve Wing Platform, sign up Wing Platform, request for services and products available on Wing Platform, performing transactions on Wing Platform and undertaking other activities on Wing Platform.
• Event: We collect information you provide to us when participating in any interactive features, contests, promotions, marketing campaigns and other activities and events related to Wing Bank or under Wing Platform.
• Third party: We collect data/information about you from third parties who are authorized by you to disclose such data to Wing Bank on behalf of yourself for processing the transactions or accessing to Wing Platform for your benefits.
• Other channels as may be applicable from time to time.

We use your data for various purposes including but not limited to:
• Respond to your requests, comments and questions and provide customer service;
• Monitor and analyze trends, usage and activities in order to operate and improve our Wing Platform and Wing Bank’s products and service;
• Manage your registered account and send you notification, notice, update, alert, support and message related to your use of services and products of Wing Bank or third parties, technical, promotional, security and other matters;
• Understand your needs and provide you with a better service and improve our services and products;
• Administer, monitor and on-going manage the services and products provided by Wing Bank or third party on Wing Bank’s distributed channels;
• Develop, deploy, manage, support and invoice for the services and products provided by Win Bank g or third party on Wing Bank’s distributed channels;
• Compile aggregate data and analysis for use internally or with third parties;
• Create and manage your account;
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Wing Platform to you;
• Send you an email;
• Enable user-to-user communications;
• Generate a personal profile about you to make future visits to the Wing Platform more personalized;
• Increase the efficiency and operation of the Wing Platform;
• Monitor and analyze usage and trends to improve your experience with the Wing Platform;
• Notify you of updates to Wing Platform;
• Offer new products, services and/or recommendations to you;
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity;
• Process payments and refunds;
• Request feedback and contact you about your use of the Wing Platform;
• Resolve disputes and troubleshoot problems;
• Respond to product and customer service requests;
• Retain for internal records in order to comply with the applicable laws;
• Carry out any other purpose for which the Data was collected; and
• Other legitimated purposes.

• Our employees, officers, commercial partners and agents to the extent as reasonably necessary for the purposes as set out in this Privacy Policy;
• Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• The vendors, consultants, sub-contractors and other service providers who need access to such data/information to carry out operation/transaction on Wing Platform;
• In response to a request for data if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
• In connection with any merger and acquisition of Wing Bank, sale of company assets of all or a portion of our business to another company or similar transactions;
• We may also share aggregated or de-identified information, which cannot reasonably be used to identify you to any person at the discretion of Wing Bank;
• government officers in response to the specific requests;
• the regulators in order to fulfill our disclosure obligation to the extent that we are required to do so by laws;
• the competent court or dispute resolution forum in connection with any legal proceedings or prospective legal proceedings; and
• any person in order to establish, exercise or defend our legal rights (including providing information to others for the purpose of fraud prevention).

Wing Bank will not disclose your Data to any third parties other than for the purpose as specified in this Privacy Policy, except that you provide consent for us to make such disclosure.

• you can request information about the Personal Data that we hold about you, what we use that Personal Data for; who it may be shared with as well as certain other information (this is called a 'subject access right'). Usually, we will have a month to respond to a 'subject access right' request although where we have a complex request, we may require a further two months to respond. We may also charge for administrative time in dealing with your request or any manifestly unreasonable or excessive requests. We may also require further information to locate specific information you seek and you should note that certain legal exemptions may also apply to what we can disclose in response;
• you can ask that we correct Personal Data that we hold about you which is inaccurate or incomplete;
• you can object to us conducting any automated processing in relation to your Personal Data (if applicable), for example if we conduct any automated credit scoring;
• you can object to us continuing to use your Personal Data to send you direct marketing;
• you can request that we erase your Personal Data if we no longer need to hold it; or
• you can ask us to transfer your electronically held Personal Data to another party where it has been collected with your consent or is being used by us to perform contract. In this case, we may also charge for administrative time in dealing with your request.

If you would like to exercise any of the rights set out above, please contact us using the contact details below. We may need to ask for evidence to verify your identity before we can fully respond.

We may share or transfer your data/information to third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

If you interact with other users of Wing Platform, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

When you post comments and content, contributions or other content which allowed by Wing Bank to Wing Platform, your posts may be viewed by all users and may be publicly distributed outside the Wing Platform in perpetuity.

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. In such event, we will immediately inform you through Wing Platform or your provided contact information.

We do not knowingly solicit information from or market to children under the legal age. If you become aware of any data/information we have collected from children under the legal age, please contact us using the contact information provided below.

This Privacy Policy is governed and construed in accordance with the laws of the Kingdom of Cambodia.

If any dispute, controversy or claim arises in relation to this Privacy Policy, the parties shall use all reasonable endeavours to resolve such dispute amicably. If the parties are unable to resolve the dispute amicably, the parties may bring the dispute to resolve by the competent court of Cambodia.

If you have any questions about this Privacy Policy or our treatment of your data/information or you would like to access your data/information, you may contact us at below:

Company: Wing Bank (Cambodia) Plc.

Tel: +855 23 999 989; or

Email: care.centre@wingbank.com.kh

Address: Wing Tower, Preah Monivong Blvd. corner Kampuchea Krom Blvd., Phum 6, Sangkat Monourom, Khan Prampir Meakkakra, Phnom Penh.