Privacy Notice 
ABACUS digital Company Limited 
For Candidate Only

We, ABACUS digital Company Limited (the “Company”, “we”, “our” or “us”), are committed to protecting the personal data of our Employees, Service Providers, Contractors, Candidates, or Participants (“you”).

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Accordingly, we provide this Privacy Notice for Employees, Service Providers, Contractors, Candidates, or Participants in activities or projects of ABACUS digital Company Limited (the “Privacy Notice”) under the Personal Data Protection Act B.E. 2562 (the “PDPA”) to inform you of the methods, objectives and details of the personal data that we collect, store, use or disclose, the duration of data collection, the disclosure of personal data, your rights as a data subject, and the measures we take to ensure the privacy and security of personal data, as well as how you can contact us.

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This Privacy Notice applies to the following natural persons:

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(1) Employees or workers of the Company pursuant to employment agreements;

(2) Service providers and contractors of the Company, including their employees or staff under the agreements with the Company (e.g. service agreement, hire of work agreement, agency contract) including its employee or staff;

(3) Job applicants, whether they are applying directly with the Company, or through agency or other entities;

(4) Former employees, of whom the Company needs to retain or use their personal data as required by laws;

(5) Parents, descendants, relatives, spouses, or beneficiaries of employees;

(6) Guarantors of employees, staff, service providers or contractors under the employment agreements, service agreements, hire of work agreements, agency contracts or other similar agreements with the Company;

(7) Speakers and lecturers for training courses organized by the Company;

(8) Trainees or participants in projects or activities organized or participated by the Company;

(9) Directors, advisors, or authorized persons of the Company;

(10) Employees of companies in SCBX Group;

(11) Reference persons in job applications or other contracts made with the Company;

(12) Student trainees, scholarship students of the Company including their guarantors or other relevant persons; and

(13) Any natural person entering into contract or participating in any activity (whether directly or indirectly) with the Company for the purposes stated in this Privacy Notice.

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1. How we collect, use or disclose your personal data

We only collect, use, or disclose your personal data where it is necessary or there is a lawful basis for collecting, using or disclosing it. This includes where we collect, use, or disclose your personal data based on the legitimate grounds of legal obligation, performance of a contract to which you are a party, our legitimate interests, performance under your consent and/or other lawful basis as permitted by law. The purposes of collection, use, or disclosure of the personal data are as follows:

1.1 Legal obligations

As the Company is subject to supervision and regulations and must comply with appliable laws and regulations, it is necessary for the Company to collect, use or disclose your personal data for various reasons as required by the following laws and governmental regulations:(1) The Personal Data Protection Act;

(2) The Civil and Commercial Code, Labour Protection Act, Labour Relations Act including other relevant labour laws;

(3) The Social Security Act, Provident Fund Act, Workmen Compensation Act, Cremation Fund Act, or other laws relating to the provision of welfare for employees or workers;

(4) The Empowerment of Persons with Disabilities Act, Skill Development Promotion Act and/or other relevant laws;

(5) The Revenue Code or other tax laws;

(6) The Orders and regulations issued by government authorities, such as court orders, orders from governmental or supervisory agencies, or regulatory authorities, etc.;

(7) The Anti-money laundering and suppression of terrorism funding (AML/CFT) laws;

(8) Checking of background, assets or securities holding of employees as required by laws, including reports made to relevant regulatory or governmental authorities; and

(9) Checking and verifying of background or qualifications for the appointment of executives or other key positions as required by rules and regulations issued by relevant regulatory authorities or other relevant laws.

1.2 Contract entered into with you

We will collect, use, and disclose your personal data in accordance with application documents, agreements, or contracts entered into with us and for the purposes stated therein, as follows:

(1) Job application, recruitment, interview, questionnaire, performance assessment of the candidate;

(2) Employment, negotiation, employment approval, preparation, modification, change, renewal, or any other actions with respect to employment agreements and/or agency agreements, including change of working conditions;

(3) Preparation of employee profile registration, book-keeping of employee profile registration on the Company’s system, including to create, delete, edit employees’ personal data and grant or revoke the rights of the employee;

(4) Preparation of payroll and calculation of wages, salaries or compensations to be paid by the Company to you, including making payments or setting aside workers compensation reserves;

(5) Arrangement for welfare, benefits, payments, loans, credits and reimbursements concerning welfare programs granted by the Company to employees;

(6) Arrangement, change, or cancellation of health insurance, life insurance, accidental insurance or other types of insurances;

(7) Grant, permission or alteration, deletion and control of the rights to access or use the Company’s assets or systems;

(8) Arrangement and provision of office equipment and supplies for employees and sales agents (e.g. uniform, name cards, signs, licenses, computers and mobiles distribution and employee or sales agent cards), including arrangement for returning of the same upon employment termination;

(9) Review and assessment for the appointment of executives or other key positions;

(10) Compliances with the employment agreement work rules, regulations and orders of the Company;

(11) Record and management of data concerning employees’ leaves and entitlement;

(12) Performance review and job assessment;

(13) Grant of scholarships and internship;

(14) Arrangements relating to termination or expiration of the employment agreement between the Company and employee, including retirement;

(15) Organization of activities by internal and external personnel;

(16) Arrangement in relation to any internal and external trainings, license acquisition, projects or employees’ or agents’ capacity development programs, including issuance of training certificates or licenses;

(17) Communications and announcements to employees related to the performance of contract via any communication channels;

(18) Use of any third-party services to perform the duties under the contract between you and the Company

(19) Preparation of Power of Attorney;

(20) Preparation of salary certificate, income statement, work certificate, or other certificates concerning employment, agency, or other types of service agreements;

(21) The analysis, evaluation, and report preparation through the Company's system for considering performance and improving employee’s work efficiency;

(22) The collection, use or disclosure of your personal data provided to the Company and/or the companies in SCBX Group for the purpose of analyzing and summarizing the overall Employee Survey, as well as for the benefit of managing human resources within SCBX Group; and

(23) The disclosure of your employment status to third parties via telephone or other channels, based on specific prior requests you have submitted to the Company on a case-by-case basis.

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1.3 Legitimate interests

We rely on legitimate interests by balancing the nature of the personal data that we collect, use, and disclose with your normal reasonable expectations and by providing safeguards to reduce any potential negative impacts on your fundamental rights and freedoms. This may include processing your personal data to:

(1) use personal data of non-applicants during the process of recruitment, interview and assessment of applicants, including to store the personal data of the beneficiaries of employees;

(2) perform duties under a contract between the Company and another person, where your personal data is necessary but you are not a contractual party;

(3) record and keep personal data on the Company's internal storage system;

(4) enhance staff knowledge and capabilities including relevant management and planning for corporate structuring projects;

(5) pursue safety and business continuity measures of the Company, the companies within SCBX Group (as listed at https://www.scbx.com/en/affiliates-financial-business-group/, and SCBX Group as a whole, including governance, auditing, risk management regarding internal personnel, and reporting operational incidents;

(6) conduct employee and agent background check of the companies within SCBX Group and SCBX Group as a whole;

(7) perform the Company’s accounting, financial, or other internal management operations;

(8) undertake measures and actions towards surveillance, prevention, investigation, complaint handling, investigation of suspicious behaviors, or fraudulent behaviors, money laundering, and terrorism misconduct, including actions to prevent such incidents;

(9) undertake and record of disciplinary action, make criminal report, give statements or information to the police, competence officer, court and other competent authorities;

(10) take action relating to disputes, dispute resolution including establish, exercise, or defend the legal claim;

(11) provide and disclose of information regarding employee status, employment information, human resource management, salary framework development, benefits, compensation, and employee welfare to third parties, such as companies within SCBX Group, etc., for the purpose of analysis and improvement to ensure alignment with the policies and standards of the companies in SCBX Group;

(12) prepare reports for the Company's internal departments including questionnaires, collecting, and analyzing various data to support the work within the organization or for planning, management, implementation of administrative measures, workforce development, or any related activities;

(13) make travel and accommodations or other facilities arrangements for employees, such as ticket and hotel reservations, meals, etc.;

(14) communicate with and make announcement to employees via any channels. This includes conversations conducted through channels established by the Company utilizing current or future technologies possessed by the Company, such as Chatbots, etc.; and

(15) membership process for cooperatives and cremation fund.

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1.4 Consent

Normally, we will not collect, use or disclose your personal data if we does not have any lawful bases to do so. However, if necessary, we will ask for your consent to collect, use or disclose your personal data for your benefits the following purposes:

(1) The Company deems it necessary to collect and use sensitive personal data, for example, for the purposes of authentication (identity verification), criminal record checks, or providing health-related benefits and welfare to employees, etc.;

(2) Checking the background of employees or agents within SCBX Group (in cases where consent is required under the PDPA);

(3) Sending or transferring your personal data and sensitive personal data internationally, where the standards for personal data protection may be inadequate (unless the PDPA permits such action under other legal bases or without obtaining consent); and

(4) When the data subject is classified as a minor, quasi-incompetent or incompetent whose consent must be given by their parent, guardian or curator (as the case may be).

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1.5 Other lawful basis

Apart from the lawful basis which we mentioned earlier, we may collect, use, or disclose your personal data based on the following lawful basis:

(1) Prepare historical documents or archives for the public interest, or purposes relating to research or statistics;

(2) Believe that the use of your personal data is of vital interest or to prevent or suppress a danger to a person’s life, body or health; or

(3) Believe that the use of your personal data is necessary to carry out a public task, or exercise official authority.

In addition, the Company may utilize technologies currently possessed or to be acquired in the future for the collection, use, or disclosure of your personal data in accordance with the purposes stated in clauses 1.1 – 1.5 above, including, but not limited to, Artificial Intelligence (“AI”), Generative AI Usage, such as AI Chatbot technology, Cloud Computing, etc.

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Furthermore, the Company may establish the system(s) to support operations and business activities for shared use within SCBX Group and may collect, use, or disclose your personal data held by the Company and the companies in SCBX Group through such system(s) in accordance with the PDPA.

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2. What personal data we collect, use, or disclose

The personal data that we collect, use, or disclose may vary depending on the objectives and necessities and may include both general and sensitive personal data, which include, but are not limited to:

Personal details

• Given name, middle name, surname, hidden name (if any)

• Gender

• Date of birth

• Age

• Marital status

• Nationality

• Educational background

• Work experience

• Military conscription or military service information (for male employees)

Contact details

• Mailing address

• House registration address

• E-mail address

• Phone number

• Facsimile number

• Social media accounts

Identification and authentication details

• Photo on ID card, employee card, or sale agent card

• House registration

• Identification number, laser number (back of identification card)

• Passport

• Driving license

• Signatures

• Tax identification number

Employment details

• Positions and responsibilities

• Salary, income and remuneration

• Leaves information

• Performance assessment

• Assessment and other evaluations

• Reimbursement and welfare usage and claims

• Disciplinary actions

Welfares and benefits

• Information relating to finance and tax

• Information relating to life insurance, health insurance and non-life insurance

• Information relating to provident fund

• Information relating to cremation fund

• Information relating to loan or debts

• Information relating to education of the employee’s child

Geographic data and data relating to your device and your software, and technical details

• GPS

• IP address

• Technical specifications and uniquely identifying data

Investigation data

• Background, anti-money laundering and counter terrorism checks

• Consent and metadata of relevant information exchanges between and among individuals and/or organizations, including emails, voicemail and live chat

• The recording of photos or videos during training sessions or examinations as required by the Company

User login and subscription data

• Login credentials for computer system and work phone

• Internet browsing history

Data concerning security and data required to support our regulatory obligations

• Visual images

• Files

• Personal appearance

• Detection of any suspicious and unusual activity

• CCTV images or recordings

• Video recordings

Sensitive personal data

• Race

• Religion

• Health-related information (e.g. blood type, health examination results)

• Biometric information (e.g. face recognition, fingerprint, retina recognition, voice recognition)

• Criminal records

• Information relating to trade union

• Disabilities

Other data

• Data relating to attendance of activities and/or records of correspondence and other communications between you and the Company, in whatever manner and form, including but not limited to video recording, photographs, phone, email, live chat, instant messages and social media communications

• Data that you provide to us through any channels
   

3. Sources of your personal data

Normally, we will collect your personal data directly from you, but sometimes we may get it from other sources, in such case we will ensure the compliance with the PDPA.

Personal data that we collect from other sources may include but not limited to:

(1) information that you have asked us to collect for you (e.g. information about your accounts or property holdings with other companies including transactional information);

(2) information of any persons relevant to you (e.g. your family, relatives, job, or scholarship guarantor) that is necessary for us to proceed with the relevant employment, benefits and welfare purposes;

(3) information from third-party service providers and/or governmental authorities (e.g. information that helps us to combat fraud or information related to your social interactions (including your communications on social media, with individuals, organizations, clearing houses, custodians, and any other stakeholders, obtained from the companies from which information is collected));

(4) information from our trusted business partners or other third parties involved in your transactions;

(5) if information arises out of your insurance policy or claims thereunder, we may also collect:

(a) information about your medical records obtained through an agreement or with your consent;

(b) information about your insurance claims history;

(c) information from other parties involved in your insurance policy or claim; or

(d) information from publicly available sources.

(6) information from CCTV and surveillance devices; or

(7) information from companies in SCBX Group, relating to your work or engagement.

Other than the above-mentioned information, we may collect personal data of the following third parties from you:

• Emergency contact;

• Guardian, family members or other individuals who have relationship with you;

• Beneficiaries to receive welfares from us; and

• Persons who you refer to in the job application or contract with us.
   

In case you have given any personal data of any other person to us for executing transactions with us or any purposes, you shall notify such person of the details relating to the collection, use, and disclosure of personal data and rights under this Privacy Notice. In addition, you shall obtain consent from such person (if necessary) or relied on an other legal basis to provide personal data to us.

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4. Your rights

The PDPA aims to give you more control of your personal data, you can exercise your rights under the PDPA, details as specified below, through the channels prescribed by us:

4.1 Right to access and obtain copy

You have the right to access and obtain copy of your personal data holding by us, unless we are entitled to reject your request under the laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.

4.2 Right to rectification

You have the right to rectify your personal data to be up-to-date, complete, and accurate at any time.

4.3 Right to erasure

You have the right to request us to delete, destroy or anonymize your personal data, unless there are certain circumstances where we have the legal grounds to reject your request.

4.4 Right to restrict

You have the right to request us to restrict the processing of your personal data under certain circumstances, for example when your personal data is pending examination process to rectify your personal data, or when it is no longer necessary for us to retain the personal data.

4.5 Right to object

You have the right to object to the processing of your personal data, except in the case where we have compelling legitimate grounds which may override your own interests, or when the processing of your personal data is carried out to comply with, exercise or defend legal claims, or if such personal data processing is necessary for the performance of a task carried out under public interests.

4.6 Right to data portability

You have the right to request us to send or transfer your personal data to third party, or to receive your personal data which we sent or transferred to third party, unless it is impossible to do so because of the technical circumstances.

4.7 Right to withdraw consent

You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us, unless the nature of consent does not allow such withdrawal. The withdrawal of consent will not affect the lawfulness of the collection, use, or disclosure of your personal data based on your consent before it was withdrawn.

4.8 Right to lodge a complaint

You have the right to make a complaint with the Personal Data Protection Committee or their office in the event that we do not comply with the PDPA.

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5. How we disclose your personal data

We may disclose your personal data to the following parties under the provisions of the PDPA:

(1) Companies in SCBX Group, business partners and/or other persons that we have the legal relationship, including our directors, executives, employees, staffs, contractors, representatives, advisors and/or such persons’ directors, executives, employees, staffs, contractors, representatives, advisors;

(2) Our customers or service receivers, where the disclosure is necessary for you to perform your duties, or it has other lawful bases to do so;

(3) Business partners, agents, third party service providers and other entities (e.g. external auditors, depositories, document warehouses providers, IT service providers), provided that the disclosure of your personal data must have a specific purpose, and is made on lawful basis, as well as is subject to appropriate security measures;

(4) Any relevant persons as a result of activities relating to sales claims and/or assets, corporate restructuring or merger of with another entity where we may transfer our rights to such merged entity including any persons with whom we are required to share data for a proposed sale claims and/or assets, corporate restructuring, merger, financial arrangement, asset disposal or other transaction relating to our business and/or assets used in its business operation;

(5) Legal counsel, attorneys, fraud prevention agencies, courts or governmental authorities or any person with whom we are required or permitted by law and other relevant regulations, court orders or other authorities, to disclose the personal data;

(6) Third-party guarantors or other persons that provide you with benefits or services associated with products and/or services (e.g. insurance company relevant to work, products, or services);

(7) Your attorney, sub-attorney, legal representatives, or authorized persons who have lawfully authorized power; and/or

(8) Governmental agencies, state enterprises, state agencies relating to the disclosure of your personal data in accordance with the law and/or regulatory authority (e.g. the Department of Labour, Legal Execution Department, Education Loan Fund, the Bank of Thailand, the Securities and Exchange Commission, the Office of the Insurance Commission, or the Ministry of Digital Economy and Society).

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6. International transfer of personal data

In case where it is necessary for us to transfer your personal data internationally, we will use our best efforts to send or transfer your personal data to reliable business partners, service providers or recipients in the safest way to keep your personal data secure, including in the following circumstances:

(1) It is required by law;

(2) In the event that the destination country does not have adequate personal data protection standards, we will ensure that the sending or transfer of personal data complies with the requirements of the PDPA, and will implement measures for personal data protection deemed necessary and appropriate to ensure that your personal data is protected under standards equivalent to those in Thailand, such as entering into agreements with the data recipient to stipulate personal data protection with adequate security;

(3) It is necessary for the performance of a contract to which you are a party or in accordance with application/request prior to execution of contract;

(4) It is necessary to comply with a contract between us and other individual or juristic parties, for your own interest;

(5) It is for a vital interest or it is to prevent or suppress a danger to a person’s life, body or health and you’re incapable of giving consent at such time; or

(6) We need to carry out activities relating to the public interest.

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7. Retention period of personal data

We will keep your personal data for as long as you still have the relationship with us as our employee, service provider, contractor, candidates, or participants in activities or projects under the employment agreement, service agreement, hire of work agreement, agency contract, or other agreements of the same kind that you have entered into with us. We will only keep your personal data for a period of time that is appropriate for the type of personal data and the purpose we hold it for in accordance with the PDPA.

The period of time that we retain your personal data is corresponding to the prescription period and law enforcement period under the laws. However, we may retain your personal data after the expiration of such period if we are obligated to do so under the laws, or if any existing claims or complaints will reasonably require us to keep your personal data, or for regulatory or technical reasons, whereby if we are required to keep your personal information for a longer period of time, we will continue to keep your personal data secure.

Apart from this, we may need to retain CCTV surveillance in our offices, records of visitors to our premises, and voice recordings to prevent fraud and for security reason, including to investigate any suspicious transactions at the request of our customers or related persons to validate those transactions.

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8. Use of Cookies

We may collect and use cookies and similar technologies when you use our systems, products and/or services, including when you use our websites for the operations and our services, electronic systems, to make transactions through internet banking, or our applications.

The collection and use of such cookies and similar technologies helps us recognize you, remember your preferences and customize how we provide our products and/or services to meet your needs. We may use cookies for a number of purposes (e.g. enabling and operating basic functions, enabling us to improve your online experiences or our communications with you, or helping us understand how you interact with our websites or emails, particularly, to ensure that online adverts displayed to you will be more relevant to you and of your interests), for details please see Cookie Notice.

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9. Use of personal data according to the original purposes

We are entitled to continue collecting and using your personal data, which has previously been collected by us before the effectiveness of the PDPA in relation to the collection, use, and disclosure of personal data, in accordance with the original purposes. If you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time.

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10. Security

We have implemented different measures to ensure that your personal data is secure, such as data encryption, and also requires our staff and third-party contractors to follow our applicable privacy standards and policies and exercise due care and implement appropriate security measures when processing your personal data.

11. How to contact us

If you have any questions or would like more details about our Privacy Notice, please contact us through the following channels:

• ABACUS digital Company Limited

our head office located at SCB Park Plaza Building, Tower 3 East, 22nd Floor, 19 Rutchadapisek Road, Chatuchak, Chatuchak, Bangkok 10900.

• Data Protection Officer

E-mail: DPO@abacusdigital.com  

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If you would like to exercise your rights in accordance with PDPA, please contact us through our head office and/or our Data Protection Officer through E-mail: DPO@abacusdigital.com

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12. Changes to this Privacy Notice

We may change or update this Privacy Notice from time to time and we will inform the updated Privacy Notice at our website: www.abacusdigital.com.

Updated March 2026