BACKGROUND INFORMATION Why do we collect information? Any of the information we collect from you may be used in one of the following ways:

• To personalize your experience (your information helps us to better respond to your individual needs)
• To improve our MULA App (we continually strive to improve our App offerings based on the information and feedback we receive from you)
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
• To process transactions
• To administer a contest, promotion, survey or other site feature
• To send periodic notifications and information

• Data on national identification card
• Account balances, payment history and transaction history
• Service usage data, such as data from mobile phone usage
• Personal scores and answers from psychometric questionnaire
• Other information you’ve filled out as part of application process

We collect data of your phone to provide a segmented risk profile and generate an aggregated statistical information for our own purposes. To protect your identity, we remove all personal identifiers (if any) and pseudonymise such information. Any metadata processed in this way cannot be used to reproduce the original data collected.

Note: For sensitive data, which is personal information regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal records, trade union memberships, biometric data, health records and sexual orientation or preferences, will be removed immediately if it is not required.

HOW?

All companies servicing customers need to share customers’ personal information in their normal operations. In the section below, we list the reasons the purposes companies can share their customers’ personal information and whether you can limit this sharing. In addition, there are certain rights you should be aware of under PDPA.

WHO?

To render the service to you, as the Data Subject, under MULA-X Application (“MULA App”), we, as the Data Controller/Data Processor, disclose your personal information strictly under consent to its employees, its representatives, auditors, and external service providers under a contract with the Company, and Data Processors. Ie. 2C2P (Thailand) Co., Ltd., Amazon Web Services.

We may disclose information (including personal information) about you to our subsidiaries and Affiliates. For purposes of this Privacy Policy, “Affiliates" means any person or entity which directly or indirectly controls, is controlled by or is under common control with MULA-X, whether by ownership or otherwise. Any information relating to you that we provide to our Affiliates will be treated by those Affiliates in accordance with the terms of this Data Privacy Policy. In addition, information disclosure may be required by the governmental agencies in accordance to the laws or government announcement. In such case, we will need to strictly obliged no matter consent is in place or not.

WHY?

We use the data collected as part of our service provided for our products so that we are able to improve the user journey and experience

TYPE OF CONSENTS AND IF YOU CAN LIMIT SHARING?

Can you limit this consent while receiving service from MULA-X?

NO. MULA-X can’t provide service to customers unless there in “consent to manage personal data” in place.

Consent to use personal data for product development

To allow MULA-X to use your personal information to develop and/or improve products and/or services that are better and suitable to your need.

Can you limit this consent while receiving service from MULA-X?

Can you limit this consent while receiving service from MULA-X?

Can you limit this consent while receiving service from MULA-X?

Please note: If you are using MULA-X services and application, you may not limit or revoke “Consent to Manage Personal Data.” An action to limit or revoke this consent will disable your eligibility to receive further service. In the case you still have a loan outstanding, you cannot revoke “Consent to Manage Personal Data”.

HOW DO WE MANAGE CUSTOMER’S PERSONAL INFORMATION How do we collect your information?

MULA-X collects your information required to render our service from three main sources:

1. Personal information provided by yourself, either through electronic capturing (e.g. using OCR technology to capture information on national identification card) or key-in information by yourself as part of application process.
2. Transactional information obtained from your past transactions and historical activities on MULA-X Application.
3. Information provided by 3rd parties such as service usage data.

What information do we collect?

We collect information from you when you visit our app, register on our site, place an order, subscribe to our newsletter, respond to a survey or fill out a form.

• Name / Username
• Phone Numbers
• Email Addresses
• Password

We also collect information from mobile devices for a better user experience, although these features are completely optional:

• Location (GPS): Location data helps to create an accurate representation of your interests, and this can be used to bring more targeted and relevant ads to potential customers.
• Phonebook (Contacts list): Your contacts list enables us to understand you (as user) better.
• Camera (Pictures): Granting camera permission allows the user to download more applications via QR code and also enables you to participate in programs that uses QR code.
• Photo Gallery (Pictures): Granting photo gallery access allows the user to upload any picture to their photo gallery, such as receipts of transactions envisaged by the app.
• Calendar: Granting calendar access allows us to understand you better.

Note: We have clear data life cycle for each type of information we collect. We will detain the information only during the required period, after which the information will be destroyed.

How do we handle a breach?

At MULA-X, we have assigned Khun Phisit Sucharitsopit, our Chief Information Officer as Data Protection Officer (“DPO”). Under our philosophy, we want to take proactive role to continuously review our Personal Data Protection Policy to ensure that customer’s information is always managed with highest security. In case there is any breach or potential issue, DPO will take immediate action to resolve the issue and report to the government within 72 hours.

Contact us
Via Email: service@mula-x.com
Via MULA App: “Support” Quick Access

Sale of or Reorganisation of Business

We reserve the right to transfer information to another Affiliate or third party in the event of a sale, merger or other transfer of all or substantially all of the assets of MULA-X or any of its Affiliates (as defined herein), or that portion of MULA-X or any of its Affiliates to which the MULA App service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the Affiliate and/or third party agrees to adhere to the terms of this Data Privacy Policy.

Changes To Our Privacy Policy

We may change our MULA App service and policies, and hence we may need to make changes to this Data Privacy Policy so that they accurately reflect our MULA App services and policies. Unless otherwise required by law, we will notify you (for example through MULA App) before we make changes to this Data Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the MULA App service, you will be bound by the updated Data Privacy Policy. If you do not want to agree to this or any updated Data Privacy Policy, you can stop using the MULA App service and/or delete your account.

Governing Law

This Privacy Policy is governed by the laws of Thailand without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Data Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US framework. The laws of Thailand, excluding its conflicts of law rules, shall govern this Agreement and your use of the MULA App.

By using MULA-X or contacting us directly, you signify your acceptance of this Data Privacy Policy. If you do not agree to this Data Privacy Policy, you should not engage with our MULA App, website, or use our services. Continued use of the MULA App, direct engagement with us, or following the posting of changes to this Data Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.