Protecting your privacy

Protecting your privacy and the confidentiality of your personal information is fundamental to the way TrueMoney does business. As a payment service institution, TrueMoney commits to fully complying with all applicable laws in Cambodia concerning privacy, including in particular all supervisory regulations of the National Bank of Cambodia as our supervisory regulator. TrueMoney has an obligation to keep customer’s personal information, including sensitive information, confidential. We value the ongoing trust you have in us to protect your privacy.

This Privacy Policy explains how TrueMoney will manage and protect your personal information, including information that TrueMoney collects during the course of providing a service to you and the information that TrueMoney holds after your product or service is terminated (where we are required to hold such information or it is necessary for regulator).

This Privacy Policy contains information about how you can access the information that TrueMoney holds about you, how you can ask TrueMoney to correct your information and how you can make a complaint if you have concerns about how TrueMoney has managed your information.

 

Our privacy framework

TrueMoney is bound by all applicable laws in Cambodia dealing and in particular Article 47 in respect of Professional Secrecy of the Cambodian Law on Banking and Financial Institutions of 1999. The National Bank of Cambodia further regulates the way that the banking and financial institutions under its supervision handle customer’s personal and sensitive information.

 

YOUR PERSONAL INFORMATION

TrueMoney collects your personal information so that we can perform our various functions and activities. TrueMoney also collects your personal information if the law requires us to collect it.

TrueMoney collects your personal information directly from you when:

(i). you open or sign up an TrueMoney account,

(ii). deal or enquire us over the telephone,

(iii). send us an email or letter,

(iv). visit or browse our TrueMoney websites, or

(v). visit our business center,

(vi). you performed transactions with TrueMoney via its Agents.

 

If you apply for a TrueMoney account or use our platform whether via TrueMoney Mobile App or transact via Agents, TrueMoney or its authorized Agents may collect and hold your personal information such as:

(i). full name,

(ii). date of birth,

(iii). gender

(iv). correspondence and/or billing address,

(v). occupation

(vi). telephone number,

(vii). e-mail address, or

(viii). a note or recording of a call that you made to TrueMoney’s hotlines

(ix). your TrueMoney account information, such as dates of payment, transfers, cash-in and cash-out information and any other information relating to your account, and

(x). other information related to your annual income and/or employment background where it is required by the Cambodian Laws and regulations.

 

Collecting information from third parties sources

For the purpose of inquiring your background to satisfy our regulatory obligation, TrueMoney may collect information about you that is publicly available, including information from:

(i). independent sources,

(ii). telephone directories, or

(iii). other reliable websites.

TrueMoney may also collect information about how you use TrueMoney via our marketing promotion activities via Facebook or digital advertising to help us better tailor our services to you. For example, TrueMoney may do this when you click on a link from an TrueMoney website, link shared on Facebook or visit a website which displays an TrueMoney advertisement.

 

Collecting sensitive information

Sensitive information is personal information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information or health information.

TrueMoney will not collect, use or disclose sensitive information about you except there is a request about you to TrueMoney from the competent authorities such as Court or the National Bank of Cambodia.

 

USING YOUR PERSONAL INFORMATION

TrueMoney may use and analyze your personal information for purposes including but not limited to:

(i). the daily operations of TrueMoney’s services to manage your TrueMoney account and other administrative and operational tasks;

(ii). verifying your identity when required;

(iii). to tell you about latest deals, offers or promotions that may be of interest to you;

(iv). designing new products or services;

(v). assisting you with any products or services enquiries and/or disputes, including investigating and resolving service affecting issues  you may have;

(vi). analysing your usage of TrueMoney platform, account and services so that TrueMoney can further improve its products and services to better serve you and all users;

(vii). assisting TrueMoney in investigating any actual or suspected fraud and crime prevention;

(viii). to consider any concerns or complaints you raise against TrueMoney and/or to manage any legal action between you and TrueMoney;

(ix). assisting competent authorities as required by the Cambodian laws and regulations;

(x). any other reasons as deemed necessary after having received your consent, both verbal or written.

 

DISCLOSING YOUR PERSONAL INFORMATION OVERSEAS

TrueMoney may need to transfer certain personal data to TrueMoney group companies or service providers outside Cambodia. The most common reason for TrueMoney  transferring your data outside Cambodia is because TrueMoney is required to:

(i). implement necessary security risk measures to back-up you and TrueMoney from risk of data losses in a disruption event.

(ii). engage with external vendors employed by TrueMoney to enhance existing TrueMoney’s current platform, mobile Application and its websites to ensure TrueMoney continues to provide better services to you

For the data transferred outside Cambodia, TrueMoney will take necessary measures to ensure that your personal data is used by the third-party in accordance with this Privacy Policy.

 

RETENTION OF YOUR PERSONAL DATA

TrueMoney will destroy any personal data it may hold in accordance with its internal policy. Personal data will only be retained for as long as TrueMoney needs it for the purposes of use stated in this policy (and directly related purposes) unless the personal data is also retained to satisfy any applicable statutory, regulatory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.

 

CONSENT ON YOUR PERSONAL INFORMATION

By confirming electronically of your agreement with TrueMoney,  you have agreed to the Consumer’s terms and conditions  which contains information about the use or disclosure of your data. And, for the purpose of usage or disclosure of your data, this will mean you expressly agree to TrueMoney for the specific use of your personal information under this TrueMoney Privacy Policy.

TrueMoney will only seek your consent to collect, use and/or disclose your information if we need to use your information for a purpose that is not related to this TrueMoney Privacy Policy.

 

MARKETING AND PRIVACY

TrueMoney intends to use your personal data such as your contact details, including contact name, mobile phone number, email address, correspondence address and other deals information you have viewed and purchased and your location data so that TrueMoney can send you information, materials, products, offers and news about the following products and services (in respect of which TrueMoney may or may not be remunerated):

(i). TrueMoney’s marketing activities including its offers and promotions;

(ii). reward, loyalty or privileges programmes and related products and services; and

(iii). promotions offered by TrueMoney from time to time.

TrueMoney will seek your consent or indication of no objection before TrueMoney uses your personal data in direct marketing.

 

MANAGING YOUR PERSONAL INFORMATION

TrueMoney protects your information. TrueMoney protects your personal information under our custody from misuse and loss. We also protect it from unauthorized access, modification and disclosure by ensuring that your personal information can only be accessed by people properly authorized to have access. TrueMoney may store your personal information in hardcopy documents or electronically. TrueMoney maintains physical security, such as locks and security systems, over our paper and electronic data stores and premises. TrueMoney also maintains computer and network security. For example, TrueMoney uses firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems. TrueMoney continually maintains and monitors its online security systems to ensure that TrueMoney’s payment platform is secure and that your personal information is appropriately protected when you use these services.

 

Protecting your privacy

You can help us to protect your privacy by observing our security requirements and contacting us immediately if your contact details change. We require you to keep your personal identification number (PIN), passwords and security code confidential and secure at all times. This means that you should not disclose your PIN, passwords or security code to any other person. You should contact TrueMoney immediately if you believe that your PIN, passwords or security code may have been stolen or accidentally disclosed to another person or if you would like to change your PIN or password.

 

UPDATING YOUR PERSONAL INFORMATION

If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you should contact us. We will promptly update any personal information that is inaccurate, incomplete or out of date. You may call our Care Center Team via our hotlines services provided in our Website or visit our office to correct information that we have received through the system or information during on-boarding. If we do not agree that your information is inaccurate, incomplete or out of date, we will write to you and tell you the reason(s) why we do not agree with you. We will also tell you what you can do if you are not satisfied with our response.

 

RESOLVING YOUR CONCERNS

You are entitled to complain if you believe that your privacy has been compromised or that TrueMoney has breached the privacy obligation. If you have a privacy complaint, you can call our Care Center hotlines services via: 023 999 639 or visit our office that you have been dealing with. Alternatively, you can email your complaint to us via:  carecenter.team@truemoney.com.kh.

If your complaint is not satisfactorily resolved, you may also contact the TrueMoney Office, who will escalate your matters to our Complaint Handling Team. The Complaint Handling Team will investigate your complaint thoroughly and report directly to the Managing Director or CEO as deem appropriate.

 

Managing your complaint

If you make a complaint, TrueMoney will respond within 48 hours to let you know who is responsible for managing your complaint. TrueMoney will try to resolve your complaint within 3-5 working days. When this is not possible, TrueMoney will contact you within that time to let you know how long we will take to resolve your complaint.

TrueMoney will investigate your complaint and where necessary, consult with other relevant departments about your complaint. TrueMoney will make a decision about your complaint, either call you or write to you to explain our decision.

 

PUBLICATION OF PRIVACY POLICY

This Privacy Policy is subject to change from time to time without prior notice and any changes will be posted on TrueMoney’s website: www.truemoney.com.kh. You are advised to check for the latest version regularly.

If there is any inconsistency or conflict between the version posted on the website and the previous versions, this version shall prevail. All handling of personal data will be governed by the most recent version of the policy.

If there is any inconsistency or conflict between the English and Khmer versions of this Privacy Policy, the English version will prevail.