Privacy Policy regarding Personal Data Processing
Effective Date: September 25, 2026
1. General Provisions
This Privacy Policy regarding Personal Data Processing (“Privacy Policy”) explains how J W Money Exchange Company Limited, operating under the Money Shop brand (“Money Shop”, “we”, “us” or “our”), collects, uses, processes, stores, discloses and protects personal data of customers and users of the Money Shop website, mobile application and related services.
Money Shop is committed to protecting the privacy and personal data of its customers and processing personal data in accordance with the Thailand Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), applicable Thai laws and regulations, and applicable contractual requirements.
This Privacy Policy applies to personal data processed through:
· the Money Shop website;
· the Money Shop mobile application;
· identity verification and electronic identification processes;
· currency exchange services;
· customer communications and support services; and
· other services provided by Money Shop.
By using Money Shop services, the customer acknowledges that their personal data may be processed as described in this Privacy Policy.
2. Definitions
For the purposes of this Privacy Policy:
2.1. Personal Data
“Personal Data” means information relating to an identified or identifiable natural person.
2.2. Processing
“Processing” means any operation performed on Personal Data, including collection, recording, organization, storage, retrieval, use, disclosure, transfer, access, modification, blocking, deletion, destruction or anonymization.
2.3. Data Subject
“Data Subject” means the individual to whom the Personal Data relates.
2.4. Money Shop
“Money Shop” means J W Money Exchange Company Limited, operating under the Money Shop brand.
2.5. Service Provider
“Service Provider” means a third-party company engaged by Money Shop to provide services necessary for the operation of Money Shop services, including identity verification, document recognition, payment processing, communications, hosting, security or other technical services.
2.6. Cross-Border Transfer
“Cross-Border Transfer” means the transfer or making available of Personal Data from Thailand to a recipient, system or service located outside Thailand.
3. Personal Data Processing Principles
Money Shop processes Personal Data in accordance with the following principles:
3.1.
Personal Data is processed lawfully, fairly and transparently.
3.2.
Personal Data is collected for specific, explicit and legitimate purposes.
3.3.
Money Shop collects and processes only Personal Data that is necessary and relevant for the applicable purpose.
3.4.
Money Shop does not collect excessive Personal Data that is not necessary for the relevant service.
3.5.
Money Shop takes reasonable measures to maintain the accuracy and completeness of Personal Data where necessary.
3.6.
Personal Data is retained only for as long as necessary for the purposes for which it was collected, unless continued retention is required or permitted by applicable law or contractual obligations.
3.7.
Money Shop applies appropriate technical and organizational security measures to protect Personal Data against unauthorized or unlawful access, use, alteration, disclosure, loss or destruction.
4. Services Available Without Registration
Money Shop provides certain functions that do not require the customer to create an account or submit identification information.
These functions may include:
· viewing current currency exchange rates;
· using the currency exchange calculator;
· viewing information about Money Shop services;
· viewing Money Shop branch locations;
· viewing directions and route information; and
· accessing other general informational content.
Registration or identity verification is not required to access these general informational functions.
Personal identification information is requested only when it is necessary for a specific service or transaction, including a regulated currency exchange transaction or another service for which customer identification is required by applicable law or necessary to provide the requested service.
5. Purposes of Personal Data Processing
Money Shop may process Personal Data for the following purposes:
· providing requested currency exchange and related services;
· identifying customers where identification is required;
· verifying identification documents;
· performing electronic identity verification;
· performing facial liveness verification where applicable;
· preventing fraud, identity theft and unauthorized transactions;
· complying with applicable customer identification and anti-money laundering requirements;
· processing and completing requested transactions;
· maintaining transaction and service records;
· providing customer support;
· maintaining and improving the security of Money Shop services;
· detecting and investigating technical or security incidents;
· complying with legal and regulatory obligations;
· responding to lawful requests from competent authorities;
· improving the quality and reliability of identity verification services; and
· performing other purposes that are directly related to the services requested by the customer and permitted by applicable law.
Money Shop does not use identification documents, facial information or verification data for advertising, behavioral profiling or unrelated commercial purposes.
6. Identity Verification and Personal Data Processing
6.1. Identity Verification
When a customer requests a regulated currency exchange service for which customer identification is required, Money Shop may require the customer to provide a valid passport or other identification document.
The identification document may be provided electronically through the Money Shop application.
The document is processed for the purposes of:
· identifying the customer;
· verifying the submitted document;
· preventing fraud and fraudulent use of the service;
· complying with applicable Thai customer identification and anti-money laundering requirements; and
· providing the requested regulated service.
The requirement to provide identification information applies only when such information is necessary for the relevant service or required by applicable law.
6.2. Personal Data Collected from Identification Documents
Money Shop collects only Personal Data contained in the identification document that is necessary for the purposes described above.
Depending on the document, this may include:
· full name;
· date and place of birth;
· sex;
· nationality;
· passport or other identification document number;
· document issue date and expiry date, where applicable;
· issuing authority and other document details;
· registered address, where contained in the document;
· photograph contained in the identification document; and
· other information printed on the submitted identification document.
Money Shop does not collect a tax identification number, telephone number or email address as part of the passport document recognition process unless such information is separately required for another clearly disclosed service.
6.3. MTS Identity Verification Service
Money Shop uses Mobile TeleSystems Public Joint Stock Company (MTS) as a contracted service provider for document recognition and verification.
The customer submits the identification document electronically through the verification functionality.
MTS processes the submitted document on behalf of Money Shop for document recognition and verification and provides the resulting recognition or verification information to Money Shop.
MTS processes Personal Data within the scope of the contracted verification services and in accordance with the applicable contractual requirements concerning Personal Data processing and security.
6.4. Processing of Identification Documents
The submitted identification document and Personal Data extracted from it may be processed electronically using automated systems.
Processing may include collection, recording, organization, storage, retrieval, use, transfer or access where necessary, clarification, blocking, deletion, destruction and anonymization.
Money Shop and its contracted service providers apply appropriate technical and organizational security measures designed to protect the information during processing.
6.5. Storage and Processing by MTS
Where the MTS verification service is used, Personal Data submitted for document recognition may be processed and stored by MTS through its information systems in accordance with the applicable service agreement and applicable data protection requirements.
The transfer and processing of such information are limited to the purposes of the contracted verification service and related purposes described in this Privacy Policy.
6.6. Service Improvement and Document Recognition Models
Under the applicable MTS service agreement, Personal Data processed for the document recognition service may also be used by MTS for activities intended to maintain and improve the quality of the document recognition service, including the development, training and improvement of document recognition models and investigation of incorrect document recognition incidents.
Such processing is limited to purposes related to the document recognition service and is not used by Money Shop for advertising, behavioral profiling or unrelated commercial purposes.
7. Facial Information and Facial Liveness Verification
7.1.
Where the facial liveness verification function is used, the customer may be asked to provide a real-time facial image through the camera of the device.
7.2.
The purpose of collecting and processing the facial image is to verify that the person participating in the identity verification process is a live person and to prevent fraudulent use of the identity verification process.
7.3.
Facial information is processed only for the specific identity verification and liveness function for which it is collected.
7.4.
Facial information is not used for:
· advertising;
· behavioral profiling;
· marketing;
· unrelated authentication purposes;
· identifying or tracking users for unrelated purposes;
· building advertising profiles; or
· selling or providing facial information to data brokers, advertising networks or similar parties.
7.5.
Where facial information is transferred to a contracted verification provider, such transfer is limited to what is necessary to provide the specific liveness verification service and is subject to applicable contractual and legal requirements.
7.6.
If the facial liveness functionality is not enabled for a particular service, Money Shop does not require a separate facial selfie solely for document recognition.
8. Legal Grounds for Processing Personal Data
Money Shop may process Personal Data where one or more lawful grounds under applicable Thai law apply, including:
8.1. Consent
Where consent is required, Money Shop will obtain the customer's consent before processing the relevant Personal Data.
8.2. Contract
Processing may be necessary to provide a service requested by the customer or to perform a contract with the customer.
8.3. Legal and Regulatory Obligations
Processing may be necessary to comply with applicable laws, regulations, regulatory requirements or lawful requests from competent authorities.
8.4. Legitimate Interests
Processing may be necessary for legitimate interests of Money Shop or another party, provided that such interests do not override the rights and freedoms of the Data Subject where applicable.
8.5. Other Lawful Grounds
Money Shop may process Personal Data on other lawful grounds permitted under the Thailand Personal Data Protection Act B.E. 2562 (2019) or other applicable Thai law.
9. Disclosure and Sharing of Personal Data
Money Shop does not sell or rent customers' Personal Data.
Personal Data may be disclosed or made available to third parties only where necessary for a lawful and stated purpose, including:
· contracted identity verification providers;
· document recognition providers;
· facial liveness verification providers;
· payment and financial service providers where necessary for a requested transaction;
· technical and hosting service providers;
· communication and customer support providers;
· security and fraud prevention providers;
· professional advisers where necessary;
· competent governmental or regulatory authorities where required or permitted by law; and
· other service providers where their involvement is necessary to provide the requested service.
Where Money Shop engages a third-party service provider to process Personal Data on its behalf, Money Shop requires the service provider to apply appropriate confidentiality, security and data protection requirements consistent with the nature of the processing and applicable law.
Third-party service providers may process Personal Data only to the extent necessary to provide the contracted service or perform another authorized function.
10. Cross-Border Transfer of Personal Data
10.1.
Certain Money Shop service providers may process Personal Data using information systems located outside Thailand.
10.2.
Where Personal Data is processed or transferred outside Thailand by a contracted service provider, Money Shop will apply the requirements of the Thailand Personal Data Protection Act B.E. 2562 (2019) and applicable regulations governing cross-border transfers of Personal Data.
10.3.
Cross-border transfers are limited to Personal Data necessary for the relevant service or other lawful purpose.
10.4.
Money Shop does not transfer Personal Data internationally for advertising, behavioral profiling or unrelated commercial purposes.
10.5.
Where appropriate and applicable, Money Shop will use contractual, organizational or other legally recognized safeguards for cross-border processing of Personal Data.
11. Personal Data Security
Money Shop applies reasonable technical and organizational measures appropriate to the nature of the Personal Data and the risks associated with its processing.
These measures are designed to protect Personal Data against:
· unauthorized access;
· unauthorized use;
· unlawful disclosure;
· alteration;
· accidental loss;
· destruction;
· unauthorized copying; and
· other unlawful or unauthorized processing.
Access to Personal Data is limited to persons and service providers who require such access for legitimate and authorized purposes.
Where third-party service providers are used, Money Shop requires appropriate confidentiality and security measures under the applicable contractual arrangements.
12. Retention and Deletion of Personal Data
12.1.
Money Shop retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected.
12.2.
Personal Data may be retained for a longer period where continued retention is required or permitted by applicable Thai law, regulatory requirements, contractual obligations, dispute resolution requirements, fraud prevention requirements or other lawful purposes.
12.3.
There is no single fixed retention period applicable to all Personal Data processed by Money Shop. The applicable retention period depends on the type of information, the purpose of processing and applicable legal or regulatory requirements.
12.4.
When Personal Data is no longer required and there is no lawful basis for continued retention, Money Shop will take appropriate measures to securely delete, destroy or anonymize the information.
12.5.
Where a contracted processor is no longer authorized or required to process Personal Data, Money Shop may require the processor to cease processing and delete or destroy the relevant Personal Data in accordance with the applicable agreement and law.
12.6.
Under the applicable MTS service agreement, MTS may be required to cease processing and ensure destruction of Personal Data following termination of the agreement, a valid request to cease processing, or achievement or cessation of the relevant processing purpose, subject to the terms of the agreement and applicable law.
13. Consent, Withdrawal and Requests
Where processing is based on consent, the customer may withdraw consent by contacting Money Shop.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Withdrawal of consent may not result in deletion or cessation of processing where Money Shop has another lawful basis or is legally required or permitted to continue processing the relevant Personal Data.
Requests may be submitted to:
support@moneyshopphuket.com
Subject line:
Personal Data Request
14. Rights of Data Subjects
Subject to applicable Thai law and any applicable legal limitations, customers may have the right to:
· request access to their Personal Data;
· request information about how their Personal Data is processed;
· request correction of inaccurate or incomplete Personal Data;
· request deletion or destruction of Personal Data where legally applicable;
· request restriction of processing where legally applicable;
· object to certain processing where legally applicable;
· withdraw consent where processing is based on consent;
· request transfer of Personal Data where the right is applicable; and
· exercise other rights provided by the Thailand Personal Data Protection Act B.E. 2562 (2019).
To exercise these rights, customers may contact:
support@moneyshopphuket.com
Money Shop may request reasonable information necessary to verify the identity of the person submitting a Personal Data request before taking action.
15. Cookies and Technical Information
When users visit the Money Shop website or use the application, certain technical information may be processed automatically where necessary for the operation, security and functionality of the service.
Depending on the service, this may include:
· device and operating system information;
· application or browser information;
· IP address;
· technical identifiers;
· log information;
· information concerning errors or technical events; and
· other technical information necessary to operate and secure the service.
Such information may be used for:
· operating the service;
· maintaining security;
· preventing fraud and abuse;
· diagnosing technical problems;
· improving reliability; and
· complying with legal obligations.
Money Shop does not use technical information for unrelated advertising or behavioral profiling purposes unless separately disclosed and permitted under applicable law.
16. Third-Party Services
Money Shop may use third-party service providers necessary to operate its services.
These may include providers of:
· identity verification;
· document recognition;
· facial liveness verification;
· payment processing;
· hosting and infrastructure;
· communications;
· security;
· fraud prevention;
· customer support; and
· other technical services.
Third-party providers process information only to the extent necessary for their authorized services and are required to maintain appropriate confidentiality and security measures.
Where a third-party provider has its own privacy policy applicable to its processing activities, customers may also be subject to that provider's privacy terms.
17. Account Registration and Account Deletion
Certain Money Shop services may require the creation of an account where an account is necessary for the requested service.
General informational functions of the application do not require an account.
Where an account is created, customers may request deletion of their account and associated Personal Data by contacting:
support@moneyshopphuket.com
Account deletion may be subject to legal, regulatory, transaction-record or other lawful retention requirements. Where information must be retained for such reasons, Money Shop will retain only the information necessary for the applicable legal purpose and will delete or anonymize it when the applicable retention requirement ends.
18. Changes to This Privacy Policy
Money Shop may update this Privacy Policy from time to time to reflect:
· changes to Money Shop services;
· changes to data processing activities;
· changes in technology;
· changes in applicable laws or regulations; or
· changes in the services provided by third-party service providers.
The updated version will be published at:
https://moneyshopphuket.com/policy
19. Contact Information
For questions, requests or complaints concerning the processing of Personal Data, please contact Money Shop:
J W Money Exchange Company Limited
Email: support@moneyshopphuket.com
Privacy Policy:
https://moneyshopphuket.com/policy