Protecting your privacy
Protecting your privacy and the confidentiality of your personal information is fundamental to the way EDEEL does business. As a financial service organization, EDEEL committed to fully comply with the National Bank of Cambodia Laws and Regulations. EDEEL has obligation to keep customer’s privacy information, including sensitive information, confidentially. We value the ongoing trust you have in us to protect your privacy.
Which EDEEL entities does this Policy cover?
All EDEEL entities including its sale agents/merchants are subject to strict standards in relation to the handling of personal information, regardless of where those entities, agents/merchants are located.
How to contact EDEEL?
Our privacy framework
EDEEL is bound by the National Bank of Cambodia’s Law on Banking and Financial Institution, art 47 of Professional Secrecy. The National Bank of Cambodia regulates the way that certain entities handle customer’s personal and sensitive information.
COLLECTING YOUR PERSONAL INFORMATION
EDEEL collects your personal information so that we can perform our various functions and activities. EDEEL also collects your personal information if the law requires us to collect it. If EDEEL does not collect your personal information, we may not be able to deal with you, or provide you with a product or service.
EDEEL collects most personal information directly from you. For example, you provide us with your information when you open or sign up an account, fill in an application form, deal with us over the telephone, send us a letter, use our websites, Application, or visit our business center, agent or merchant. If you apply for one of EDEEL’s products or services, EDEEL may collect and hold information from you such as your name, address, telephone number, e-mail address, date of birth, annual income and other financial details, place of work, personal and/or employment background, and your transaction history.
Collecting information from third parties
EDEEL may also collect information about you that is publicly available, including information from telephone directories, the electoral roll or other websites. There may be occasions when EDEEL collects personal information about you from a third party. For example, EDEEL may collect personal information from:
- credit reporting bodies if we request a report about your credit history;
- Intelligent company for inquiring of your background to satisfy our regulatory obligation
- other credit providers if we request information from them about the products they provide to you;
- organizations that EDEEL has an arrangement with to jointly offer products and/or has an alliance with to share information for marketing purposes to provide you with products or services and/or to promote a product or service;
- our related agents/merchants so we can better manage your relationship with all EDEEL;
- marketing companies if we acquire contact information to tell people about EDEEL products and services that may interest them; and brokers and other parties who may have introduced you to EDEEL.
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.
EDEEL will not collect, use or disclose sensitive information about you unless we need the information for one of our functions or activities and we have your consent (or we are legally required to do so). For example, EDEEL’s merchant collects personal information from you with your consent to assess your application before sign you up for an account. EDEEL may also collect information about you through customer surveys or questionnaires so that it may obtain your feedback and provide further information to you about EDEEL’s products or services.
Collecting information required by law
EDEEL may collect information from you because we are required or authorized by the National Bank of Cambodia law and regulation or court or tribunal order to collect that information. We will tell you if collection is required or authorized by law and provide you with details of the law, court or tribunal order. For example, when you open an e-wallet account, EDEEL is required under the Anti-Money Laundering and Counter-Terrorism Financing regulation to collect certain information from you to prove your identity, such as a copy of either your National ID, Passport or driver’s license.
USING YOUR PERSONAL INFORMATION
We may use and disclose personal information we collect about you for several purposes including:
- to consider your request for a product or service;
- to enable EDEEL and its agent/merchant to provide a product or service;
- to tell you about other products and services that may be of interest to you;
- to assist in arrangements with other organizations (such as loyalty partners) in relation to the promotion or provision of a product or service;
- to manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing and staff training, collecting debts and market or customer satisfaction research);
- to consider any concerns or complaints you raise against EDEEL and/or to manage any legal action between you and EDEEL;
- to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
- to identify you or establish your tax status under any local regulation pursuant to an agreement with any tax authority; and
- as required by relevant laws, regulations, codes of practice and external payment systems.
DISCLOSING YOUR PERSONAL INFORMATION OVERSEAS
EDEEL may need to disclose your information to organizations located overseas. The most common reason for EDEEL disclosing information overseas is because we use service providers to perform some functions on our behalf, and some of these service providers are located overseas. We only disclose your information to these organizations when it is necessary for the services they provide EDEEL.
For the most part, these service providers are related entities of EDEEL which perform a range of technology, operational and customer service functions for EDEEL.
These entities are located in the following countries:
- Hong Kong
EDEEL may also use other offshore service providers to help provide you with our products and services or identify ways to improve our service to you.
The above is not a complete list of the countries to which your information may be disclosed when using an EDEEL product or service. In some circumstances, the nature of the product or service you request may require EDEEL to disclose your information overseas and the countries to which we may disclose your information will depend on the particular circumstances.
YOUR CONSENT IS IMPORTANT
EDEEL may require your consent to use and/or disclose your information in particular ways. Like wise we need your consent if we need to use your information for a purpose that is not related to the purpose for which we collected your information in the first place. Depending on the circumstances, this consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to your product terms and conditions which contains information about the use or disclosure).
MARKETING AND PRIVACY
As part of our service to you, we may use personal information we have collected about you to identify a product or service that may benefit you. The EDEEL business you deal with may contact you from time to time to let you know about new or existing products or services. It may also disclose your personal information to related EDEEL entities or business partners to enable them to tell you about a product or service.
You can contact the relevant EDEEL business you deal with at any time if you do not want to receive marketing information from them. The relevant contact details for each relevant EDEEL business is as follows:
EDEEL will not use any personal information that we have received from client for marketing purposes.
MANAGING YOUR PERSONAL INFORMATION
EDEEL protects your information. EDEEL protects your personal information from misuse and loss. We also protect it from un-authorized access, modification and disclosure by ensuring that your personal information can only be accessed by people properly authorized to have access. EDEEL may store your personal information in hardcopy documents or electronically. EDEEL maintains physical security, such as locks and security systems, over our paper and electronic data stores and premises. EDEEL also maintains computer and network security.
For example, EDEEL uses firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems. EDEEL continually maintains and monitors its online security systems to ensure that EDEEL’s online payment services are 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 access codes confidential and secure at all times. This means that you should not disclose your PIN, passwords or access codes to any other person. You should contact EDEEL immediately if you believe that your PIN, passwords or access codes may have been disclosed to another person or if you would like to change your PIN or password.
HOW DO I ACCESS MY PERSONAL INFORMATION?
Subject to some exceptions, you can find out what personal information EDEEL holds about you, including what information we have obtained in our system. You should contact EDEEL if you wish to find out about the personal information an EDEEL company holds about you. We will need to verify your identity before giving you access.
We will normally be able to deal with your request immediately. If the request is complex, we will ask you to complete a personal information request form. We can usually deal with such a request within 3 to 5 working days.
Depending on the complexity of your request, we may charge a fee for processing the request. Please refer to our fees and charges booklets for our standard fees and charges.
EDEEL will usually provide access to your information at the business center or office closest to you in order to protect the confidentiality and security of your information. However, you may elect to receive your information by registered mail or courier, where practicable.
In certain circumstances, EDEEL may not be able to tell you what personal information is held about you. In these circumstances, we will write to you to explain why we cannot provide you with the information and attempt to find alternative means to enable you to access your information.
HOW DO I REQUEST CORRECTION OF MY 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 ask EDEEL or its sale agent/merchant to correct information that we have received through the system or information during on-boarding at the first place. 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 EDEEL has breached the Privacy obligation. If you have a privacy complaint, you can contact our business staff, sale agent and merchant that you have been dealing with. Alternatively, you can lodge a complaint online at www.edeel.com or contact our Customer Response Centre. The Customer Response Centre’s contact details are:
If your complaint is not satisfactorily resolved, you may also contact the EDEEL Business Center, who will escalate your matters to our Complaint Handling Team. The Complaint Handling Team will investigate your complaint thoroughly and report direct to the CEO as deem appropriate.
The Customer Complaint Team’s contact details are:
Managing your complaint
If you make a complaint, EDEEL will respond within 48 hours to let you know who is responsible for managing your complaint. EDEEL will try to resolve your complaint within 3-5 working days. When this is not possible, EDEEL will contact you within that time to let you know how long we will take to resolve your complaint.
EDEEL will investigate your complaint and where necessary, consult with other relevant departments about your complaint. EDEEL will make a decision about your complaint and write to you to explain our decision.