Privacy Notice for KUB Wallet User

Bitkub Blockchain Technology Co., Ltd.

Bitkub Blockchain Technology Co., Ltd. (the “Company”) respects and recognizes the importance of the right to privacy and the protection of User’s personal data, To ensure that User’s personal data is protected in accordance with the Personal Data Protection Act B.E. 2562, the Company has created this Privacy Notice to inform User of the details and purposes of how the Company collects, uses, and discloses User’s personal data (collectively called “Processes” “Processed” or “Processing”) as follows.

1. Person whom the Company Processes personal data

User means the person as follows:

  1. Natural person who uses or will use KUB Wallet (“Product”) or contact the Company for the information of the Product or receives the advertisement relevant to the Company’s Product.

  2. Natural person who relevant to or being the representative of juristic person who use or will use the Product or contacts the Company for the information of the Product or receives the advertisement relevant to the Company’s Product such as executive, director, employee, agent, representative, or other related natural person who is a contact person, product or service receiver, person who act on behalf of juristic person, or person whose personal information shown on the relevant business document with the Company.

  3. Natural person who has the authority to grant permission, consent or provide any certification necessary to enable the Company’s User who are legally incapacitated to use the Company’s Product as specified in the Company’s Terms of Service or is a person who must act on behalf of or jointly with such incapacitated person in exercising their rights under applicable law, such as a parent or guardian giving consent together with a minor.

2. Personal data collected, used and disclosed by the Company

The Company Processes various types of personal data which including but not limited to these personal data as follows:

  1. Identity data such as name, middle name, surname, name title, date of birth, nationality, gender, data appearing on the front of the national identification card, the code on the back of the national identification card, and information relating to government-issued documents (such as national identification card data and passport data)

  2. Family history and marital status data such as spouse and children details, a copy of marriage certificate, a copy of divorce certificate, and a copy of court order relating to marital status

  3. Transaction and financial data such as assets and income (such as profession, income, source of income, net asset value, name of the organization where employed, and work permit)

  4. Minor verification data such as parent’s name and surname, a copy of house registration, a copy of adoption certificate, a copy of court order of guardianship, and parental verification document

  5. Photo and video data such as personal photo and a front-facing photo together with the verification document

  6. Contact data such as email, phone number, address according to the identification card, contactable address, and work address

  7. Technical data such as password, PIN code, client ID, and IP address

  8. Transaction and finance data such as Wallet address, Transaction data, bank account name, money transfer slip or transfer evidence, and refund request data

  9. Service relevant data such as verification status, wallet setup status for transfers, face-scan (Biometric) setup status for accessing the Application, Token or NFT holding data, activity participation data, Airdrop reward data, lock KUB status, email connection status, PIN code setup status, password setup status, order number, package data, transaction status, merchant code, and account transferring status

  10. Sensitive data such as biometric data, biometric data comparison result, and ethnicity

  11. Contract relevant document such as power of attorney, a copy of the certificate of juristic person registration, a copy of the company affidavit, a copy of the Memorandum of Association (Bor Or Jor 2), a copy of the company’s Articles of Association, a copy of the VAT registration certificate (Por Por 20), and a copy of the list of shareholders (Bor Or Jor 5)

  12. Legal obligation data such as police warrant and a copy of the bankruptcy examination result

  13. Politically exposed data such as politically exposed person’s name and political position

3. Source of User’s personal data

The Company may collect User’s personal data from various sources for where necessary for the performance of the contract, compliance with a legal obligation, and for the purposes of legitimate interest pursued by the Company or by a third party or other stakeholders. The collection of such personal data shall be carried out lawfully, or the User has given consent for the disclosure of the personal data to the Company. In this regard, the Company collects User’s personal data from these sources as follows:

  1. The Company collects User’s personal data directly from User when using the Product’s application or website including when User contacts the Company through its communication channels such as email, phone, and social media

  2. The Company collects User’s personal data from the affiliated company of Bitkub group company where it is necessary for such company to disclose the User’s personal data to the Company.

  3. The Company collects User’s personal data from government authorities and/or regulatory authorities exercising their powers under applicable laws.

4. Collection, Use and Disclosure of personal data

The Company Processes User’s personal data under the legal bases or exemption provided under the Personal Data Protection Act B.E. 2562 including for the performance of the contract for using the Company’s services, for compliance with the law, notices, and regulations, and for the legitimate interest pursued by the Company or by a third party or by other stakeholders.

When using the Product, the Company may disclose certain of the User’s personal data to the third parties for the purpose of operating and providing service. The Company shall take the necessary measures to ensure that the User’s personal data is disclosed, transmitted, and/or transferred only to the extent necessary and in accordance with applicable laws. In this regard, the Company Processes User’s personal data under the legal bases or exemptions provided by the applicable laws, including but not limited to the following:

1. For the performance of the contract

The Company Processes User’s personal data for the performance of the contract for the purposes as follows:

  1. KUB Wallet account registration

  2. Changing KUB Wallet password

  3. Changing email and phone number linked to the KUB Wallet account

  4. Suspension and unsuspension KUB Wallet account

  5. Verifying User identity via Know Your Customer (KYC) process for natural person Users

  6. Transferring Token to KUB Wallet account or to other accounts

  7. Transferring NFT via KUB Wallet account

  8. Airdrop receiving via KUB Wallet

  9. Transferring and connecting data via Open Authorization (OAuth) technology

  10. Locking Token on a Smart Contract

  11. Dropzone activity

  12. Redeeming rewards in KUB Shop

  13. Using Programmable Payment such as topping up, transferring, or withdrawing Thai Baht, and refunding goods

  14. Verifying bank account ownership

  15. Organizing campaigns or activities through social media such as Facebook, Google Form and delivering rewards to User

  16. Registering to participate in marketing-promotion and public-relations activities, including delivering rewards for participation in such activities

  17. Receiving reports of problems in using the Product

  18. Closing the KUB Wallet account

1. Legitimate interest

The Company Processes User’s personal data under the Company’s legitimate interest for the purposes as follows:

  1. Verifying User identity via Know Your Business (KYB) process for juristic person Users, in which the data of the representative or agent of the juristic person appears

  2. Parental verification where a minor gives or withdraws consent under the personal data protection law

  3. Managing disputes or lawsuits related to User accounts, such as where the User has been defrauded or deceived

  4. Internal audit, complain management, and corruption prevention for good governance and also for complying with the law

  5. Investigating and resolving problems of Product Users

1. User’s consent

The Company Processes User’s personal data only when obtained User’s explicit consent for the purposes as follows:

  1. Verifying User identity with sensitive data via Know Your Customer (KYC) process for natural person Users

  2. Communicating and presenting the marketing benefits of the Company’s products and/or marketing-promotion activities via email

1. For compliance with the legal obligation

The Company Processes User’s personal data for compliance with the legal obligation for the purposes as follows:

  1. Tax procedures in case that User received the reward worth more than 1,000 baht

  2. Take down notice management or notification in case of inappropriate content according to the announcement of the Ministry of Digital Affairs

  3. Internal audit, complain management, and corruption prevention for good governance and also for complying with the law

  4. Sending transaction history reports to the relevant authorities

Remark: In case that User refuses the Company to Process User’s personal data which is necessary for the performance of the contract or to compliance with the legal obligation, the Company may not provide the service for User.

5. Disclosure or transfer to third parties

The Company may disclose or transfer User’s personal data to external persons or agencies only to the extent necessary and appropriate, and shall provide adequate measures to protect the personal data. The Company may disclose User’s personal data to third parties, for example:

1) The Bitkub Group Company

The Company may disclose User’s personal data to, or allow access by, other companies within the Bitkub Group Company for the purposes specified in this Privacy Notice. Such disclosure shall be made only to the extent necessary and under the relevant legal bases.

2) Government agencies with regulatory authority under the law

The Company may disclose User’s personal data to government agencies, regulatory authorities, courts, or persons having legal authority, where the Company has a legal duty to disclose or upon receipt of an order, request, court warrant, or administrative order made under lawful authority, including for the purposes of judicial proceedings, law enforcement, or protection of the rights of the Company or other persons as prescribed by law.

3) The Company’s advisors

The Company may disclose User’s personal data to the Company’s advisors for the purpose of providing advice or auditing, or for the benefit of the Company’s business operations, dispute management, or compliance with relevant laws.

6. Sending or transferring User’s personal data to foreign country

1.  The Company may transfer User's personal data to a foreign country only where the User has given consent or where such transfer necessary for compliance with applicable laws, or for the performance of a contract to which the User is a party, or the performance of a contract between the Company and another natural or juristic person for the benefit of User.

2.  The Company will comply with applicable laws and take the necessary measures to ensure that the User's personal data transferred to foreign country by appropriated safeguards.

7. Personal data retention period

The Company stores User’s personal data only for the period necessary to achieve with the purposes notified above, to comply with the contract and applicable laws, or to exercise legal claims and for the legitimate interests of the Company or other stakeholders as set out in the Company’s personal data retention policy. The Company shall delete or destroy User’s personal data or make it anonymous when it is no longer necessary for the purposes for which it was Processed or when the retention period specified in the Company’s retention policy expired.

8. Security measures

The Company values the security of User’s personal data. In this regard, the Company has put in place appropriate security, technical, and administrative measures to ensure that User’s personal data is not accessed, modified, changed, deleted, or destroyed by any unauthorized person. A review of such measures is organized when necessary or when the technology changes to ensure that information security is always effective.

9. Exercising User’s rights as a data subject

The User may exercise any right available to the User under Personal Data Protection Act B.E. 2562, as well as applicable laws, notifications, rules or regulations including:

1. Right to withdraw consent:

User has the right to withdraw the consent to Processing of personal data previously given to the Company at any time while such personal data is retained by the Company, unless the exercise of such right is subject to other legal restrictions.

2. Right to access and request to disclosur of the source of User’s personal data:

User has the right to request access to the User’s personal data collected, used, and disclosed and have the right to request the Company to disclose the source of User’s personal data.

3. Right to rectification:

User has the right to request that the Company to correct any inaccurate, incomplete personal data , or not up to date.

4. Right to erasure User’s personal data or anonymize data:

User has the right to request the Company to erase, destruct, or anonymize User’s personal data where it is no longer necessary forthe purposes determined by the Company.

5. Right to restriction of Processing User’s personal data :

User has the right to request the Company temporarily restrict the Processing of User’s personal data where the Company is verifying a request for rectification or considering objection to the processing of personal data, or where the Company no longer required to retain the personal data and is required by applicable laws to erase or destroy it,but User request that the Processing be restrictedinstead.

6. The right to data portability in the form of automated mean :

User has the right to request to transfer of User’s personal data by automated means to another data controller, unless such transfer cannot be carried out due to technical limitation.

7. The right to object the processing:

User has the right to object the Processing of the personal data in certain circumstances.

User may not be able to exercise the rights set out above, or the exercise of certain right may be subject to a fee, where:

  1. the request is contrary to, inconsistent with, or does not comply with the rights prescribed under the Personal Data Protection Act B.E. 2562, or any other applicable laws or notifications;

  2. the request is contrary to applicable law or a court order;

  3. the exercise of the right may adversely affect the rights and freedoms of other persons;

  4. the right is exercised in bad faith, is excessive, or is unreasonable; or

  5. the exercise of the right may affect an investigation, the exercise of rights in judicial proceedings, or court proceedings or adjudication.

User can exercise User’s right by summiting a request to

Please note that the exercise of right mentioned above may lose User some benefit or privilege from the Company’s service.

10. Notification of changes

The Company values the respect of User’s privacy and the accuracy of User’s personal data. If User’s Personal Data has changed, please inform the Company immediately.

11. Right to investigate and file a claim

In the event that User finds that the Company has incorrectly Processed User’s personal data or that the personal data breach has occurred, User has the right to lodge a complaint with the committee responsible for considering the complaint under the Personal Data Protection Act B.E. 2562, or to file a lawsuits and request an investigation into any act that violates User’s rights under applicable law.

12. Contact details

email: