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Privacy Policy
1. Introduction & Policy Commitment
Earnex Company Limited ("the Company" or "Earnex") recognizes the importance of protecting the personal data of all users who access our services, whether on our website, application, or any other related services. We are committed to maintaining the security of personal data and operating in accordance with the highest standards of data security to build trust and confidence among our users.
This Privacy Policy has been established to explain the manner in which Earnex collects, uses, discloses, and protects users' personal data, as well as the rights of data subjects and the methods for contacting us should users have any questions or requests concerning their data. By using Earnex's services, you are deemed to have read, understood, and consented to all terms within this policy.
User privacy is one of our core values, and we will not use your personal data for any purpose other than those explicitly stated. Earnex will comply with Thailand's Personal Data Protection Act (PDPA) and relevant international standards to ensure that your data is secure and used appropriately throughout the duration of our service.
We recommend that you read this policy carefully to understand your rights and our approach to protecting your information. If you do not agree with any part of this policy, please cease using Earnex's services. You may contact us for further clarification at any time.
2. Definitions
For clarity in understanding this Privacy Policy, the following terms shall have the meanings set forth below:
1. "Personal Data"
Means any information that can identify an individual, either directly or indirectly, such as full name, national identification number, trading account number, email address, phone number, address, bank account information, etc.
2. "Data Subject"
Means the natural person who owns the personal data that is collected, used, or disclosed by Earnex.
3. "Technical Data"
Means information about devices or website access, such as IP Address, browser type, operating system version, cookie data, access times, and clicks on the website.
4. "Cookies"
Means small data files that a website sends to and stores on a user's device to remember their usage and enhance service efficiency.
5. "User Account"
Means the account that a client registers for and uses through the Earnex system to access various services, including the Dashboard, rebate withdrawals, and broker connections.
6. "Transactional Data"
Means data related to a client's financial activities, such as rebates received, withdrawal history, and trade records linked to a broker account.
7. "Business Partner"
Means a company, broker, or external service provider with whom Earnex collaborates to provide services or process rebates.
8. "Data Controller"
Means Earnex, which is responsible for making decisions regarding the purposes and methods of collecting, using, or disclosing personal data.
9. "Data Processing"
Means any operation performed on personal data, such as collection, use, disclosure, transfer, modification, deletion, or destruction of data.
10. "Withdrawal of Consent"
Means the act of a Data Subject notifying Earnex of their wish for the company to cease collecting, using, or disclosing their data.
11. "PDPA" (Personal Data Protection Act B.E. 2562 (2019))
Means the Thai law that establishes the principles for collecting, using, and disclosing personal data to protect the rights of data subjects.
3. Types of Personal Data Collected
Earnex may collect and process your personal data as necessary to provide our services. The types of data collected can be classified as follows:
1. Personally Identifiable Information (PII)
  • Full name
  • Date of birth
  • National ID or passport number (only for identity verification purposes)
  • Nationality
    • 2. Contact Information
  • Registered or current address
  • Phone number
  • Email address
    • 3. Account and Transactional Information
  • Bank account number
  • Bank account name
  • Details of withdrawals or rebate receipts
  • Transaction history (e.g., withdrawal date, withdrawal amount)
  • Trading account details (MT4/MT5)
  • History of broker connections and traded lot volume
    • 4. Login and Usage Information
  • Username and (encrypted) password
  • Login tokens
  • Login history (time, IP Address, device used)
    • 5. Technical Data
  • IP Address
  • Browser type and operating system used
  • Time of service access
  • Cookies and session data
  • Usage behavior (e.g., clicks, pages visited, duration of use)
    • 6. Communication Data
  • Details of communications with the Earnex team (messages, images, attachments)
  • Request forms, support via chat, email, or other channels
  • Messages or comments submitted by users through the platform's contact channels
    • 7. Data from Third Parties (if any)
  • Data from partner brokers (e.g., lot volume, trading returns, account status)
  • Data from affiliates or referral partners
  • Data from external tracking systems (Facebook Pixel, Google Analytics, etc.)
    • 8. Data from Mobile Device Usage (if applicable)
  • Device type, model, operating system
  • Location (if permission is granted)
  • Push Notification ID
    • 4. Methods of Data Collection
    Earnex may collect users' personal data using the following methods:
    1. Directly from the User
    We collect data when a user:
  • Registers for a user account via the Earnex website or platform.
  • Fills out forms for service application, trading account connection, or withdrawal requests.
  • Contacts our support team (via Live Chat, LINE, Email, or contact form).
  • Participates in activities, promotions, or campaigns organized by Earnex.
  • Subscribes to our email newsletter.
  • Responds to questionnaires or satisfaction surveys.
    • 2. Automated Collection
    Earnex may automatically collect data when you use our website or platform, such as:
  • Device information: device type, operating system, device model.
  • Usage data: pages you visit, time of use, links clicked.
  • Login data: IP address, browser type, language, time zone.
  • Cookies and similar technologies, such as Pixels and Tag Managers (to collect non-identifiable user behavior).
    • 3. Collection from Third Parties
    Earnex may receive information about you from trusted external sources, such as:
  • Partner brokers with whom you connect your trading account to receive rebates (data related to trading, e.g., lot volume, trade date, account type).
  • Advertising or analytics platforms (e.g., Facebook, Google Analytics) for retargeting services or user behavior analysis.
  • Identity verification systems (KYC/AML) in cases where Earnex must verify identity information in accordance with legal requirements.
    • 4. Data Aggregation and Analysis
    Data obtained through the methods above may be analyzed collectively to:
  • Improve your user experience.
  • Customize content, offers, and promotions for individuals.
  • Monitor for security, abnormal behavior, or fraudulent use.
    • 5. Purposes for Using Personal Data
    Earnex collects, uses, and processes users' personal data with the primary objectives of providing a secure, efficient, and user-centric service. The details are as follows:
    1. To Effectively Provide the Earnex Platform
  • To register and verify user identity.
  • To open a user account on the platform.
  • To connect a user's trading account with partner brokers.
  • To display rebate information and trade records on the Dashboard. Dashboard
    • 2. To Process Transactions Related to the Rebate System
  • To calculate returns (rebates) from users' trading activities.
  • To verify the accuracy of account connection and rebate information.
  • To process rebate payments according to specified cycles or conditions.
  • To confirm and record users' withdrawal transaction history.
    • 3. For Communication and Customer Support
  • To provide assistance and answer inquiries through the Customer Support team.
  • To notify users of account connection status, withdrawals, or other important events.
  • To send announcements, news, system updates, or changes to terms of use.
  • To send satisfaction surveys to improve service quality.
    • 4. For System Development and User Experience Enhancement
  • To analyze customer usage behavior.
  • To improve the UX/UI design of the website and system for greater ease of use.
  • To evaluate and enhance the performance of existing features and develop new features that meet user needs.
    • 5. For Marketing and Promotions (with consent)
  • To send news, promotions, or exclusive offers to specific groups via email, LINE, or SMS.
  • To conduct retargeting or remarketing through advertising platforms like Facebook and Google.
  • To analyze statistical data to define target audiences and adjust marketing plans.
    • 6. To Comply with Legal Obligations
  • To retain data in accordance with the requirements of regulatory authorities.
  • To disclose data upon order from a court or government agency with legal authority.
  • To prevent illegal activities such as money laundering or fraud.
    • 7. To Maintain the Security of the System and Users
  • To monitor and prevent unauthorized access to the system.
  • To record behavior that may constitute a violation of the terms of use.
  • To analyze and issue alerts for system or user account irregularities.
    • 6. Sharing/Disclosure of Personal Data
    Earnex will not disclose or sell users' personal data to third parties for marketing purposes without your prior consent, except where necessary for the purposes previously stated or under legal exemptions. Earnex may disclose your data to the following external persons or entities:
    1. Affiliates or Partners of Earnex
  • To provide interconnected services, such as connecting a trading account with a broker or operating the Rebate system.
  • Partners involved in organizing promotions, providing support services, or systems related to Earnex's services.
    • 2. Third-party Service Providers
  • Providers of cloud systems, data analytics, email systems, and payment systems.
  • System development companies or security service providers contractually bound to protect your data.
  • KYC/AML (Know Your Customer / Anti-Money Laundering) service providers for identity verification.
    • 3. Governmental or Legal Authorities
  • Upon a lawful request from a court, regulatory body, or government agency.
  • When necessary to comply with the law or to reasonably protect the rights, safety, and property of Earnex or others.
    • 4. Disclosure in Special Cases
  • If Earnex has reason to believe that disclosure is necessary to:
  • Prevent a threat to the life or safety of any individual.
  • Investigate violations of the terms of use, IB system, or improper conduct such as money laundering.
  • Undertake legal proceedings, such as in a dispute resolution.
  • Transfer data in the event of a merger, sale of assets, or business dissolution.
    • 5. Disclosure of Non-identifiable Data
  • Earnex may disclose non-identifiable data (e.g., statistics, trend data, or aggregated analysis) for service development, strategic planning, or marketing purposes without affecting the privacy of individual users.
    • 7. Rights of the Data Subject
    Earnex respects the rights of all data subjects. You may exercise your rights as stipulated by personal data protection laws, which include the following principal rights:
    1. Right of Access
    You have the right to request a copy of your personal data held by Earnex and to be informed of how Earnex obtained it, what it is used for, with whom it is shared, and where it is stored.
    2. Right to Rectification
    If your personal data is inaccurate, not current, or incomplete, you have the right to request that Earnex correct it.
    3. Right to Erasure
    You have the right to request that Earnex delete or destroy your personal data in cases where:
  • The data is no longer necessary for the purposes for which it was retained.
  • You withdraw your consent for data collection (and there is no other legal basis for retaining it).
  • The data was unlawfully collected or used.
    • 4. Right to Restriction of Processing
    You may request that Earnex temporarily restrict the use of your personal data, for example, while awaiting verification of the data's accuracy or during the review of a data deletion request.
    5. Right to Object
    You have the right to object to the processing of your data in certain cases, such as for direct marketing purposes or for use in the public interest/for legal purposes.
    6. Right to Withdraw Consent
    Where Earnex relies on your "consent" as the basis for collecting, using, or disclosing data, you may withdraw that consent at any time. The withdrawal will not affect processing that occurred prior to the withdrawal.
    7. Right to Data Portability
    You have the right to receive your personal data in a portable format and to request that Earnex transmit that data to another data controller, subject to legal conditions.
    8. Right to Lodge a Complaint
    If you believe that Earnex or any person has used your data unlawfully or has not complied with the Personal Data Protection Act, you may file a complaint with the Office of the Personal Data Protection Committee (PDPC).
    8. Data Retention and Retention Period
    Earnex will retain users' personal data in a secure format and will implement appropriate data protection measures in line with industry standards to prevent unauthorized access, use, disclosure, modification, or destruction of data, in both digital and documentary forms.
    The company will retain users' personal data for the period necessary for the service purposes specified in this policy or to comply with relevant legal requirements. The retention periods may be as follows:
  • Account Registration and Usage Data: Retained for the duration the account remains active and for a subsequent period of up to 10 years after account termination, in accordance with applicable legal requirements (e.g., anti-money laundering laws).
  • Transactional Data: Retained for no less than 5 years from the date of the last transaction for auditing purposes and to comply with tax and financial obligations.
  • Technical Data, such as IP Address and Access Logs: Retained for 1-2 years for security, system, and technical analysis purposes.
  • Marketing Data (Marketing consent): Retained as long as you do not withdraw your consent and will be deleted within a reasonable period following a withdrawal of consent.
    • Upon the expiration of the specified period or when there is no longer a need to retain the data, Earnex will securely delete, destroy, or anonymize the data from the system using appropriate methods to ensure it can no longer identify an individual.
    Users may submit a request to delete their personal data or to check its retention status by contacting us via email: support@earnex.ai.
    9. Use of Cookies and Other Tracking Technologies
    To enhance website performance and improve user experience, Earnex may use Cookies and other Tracking Technologies to automatically collect certain types of information, such as website usage behavior, access patterns, device information, and interaction data on web pages.
    Types of Cookies Used:
    1. Strictly Necessary Cookies:
    Essential for basic website functionality, such as logging in, navigation, and user account security. Without these cookies, some parts of the system cannot function.
    2. Performance Cookies:
    Used to measure and analyze website usage, such as visit frequency and popular pages, to improve functions and content.
    3. Functionality Cookies:
    Help remember user settings, such as language or region, to provide a more convenient and personalized website experience.
    4. Targeting/Advertising Cookies:
    Used to present content, advertisements, or promotions relevant to the user's interests. They may be linked to third-party tracking systems such as Facebook Pixel, Google Ads, or TikTok Pixel.
    Other Tracking Technologies Earnex May Use:
  • Web Beacons / Pixels: Small files that help track whether an email or web page has been opened.
  • UTM Parameters: Tracking codes that help identify the source of a user, such as from which advertisement or campaign they came.
  • Local Storage / Session Storage: Used to store data within the browser to speed up loading times.
    • Cookie Management by Users:
    Users can control or disable the use of cookies through their browser settings. The method may vary by browser, such as Chrome, Safari, Firefox, or Edge. Please note that disabling certain types of cookies may prevent you from using some functions of the Earnex website to their full extent.
    Use of Data from Cookies:
    Earnex uses data from cookies for the following purposes:
  • To analyze user behavior on the website.
  • To improve the personalized user experience.
  • To present content and advertisements that match user interests.
  • To evaluate and enhance the effectiveness of marketing campaigns.
  • To monitor for irregularities or behavior that may violate the terms of use.
    • 10. Data Security Measures
    Earnex places the highest priority on protecting users' personal data to prevent data leakage, loss, or unauthorized access, use, or disclosure. The company has implemented multi-level security measures as follows:
    1. Data Encryption
  • Use of international standard SSL (Secure Socket Layer) encryption technology for data transmission between the user and the server.
  • Sensitive data, such as passwords and financial information, is encrypted and inaccessible to external parties.
    • 2. System and Server Security
  • Use of Firewalls and protection systems against external attacks (DDoS Protection, Brute-force Protection).
  • Regular updates to security systems.
  • Data is stored on servers with data center-level security.
    • 3. Access Control
  • Access to personal data is restricted to authorized employees or officers only.
  • An Audit Trail system is in place to track and log data access.
    • 4. Security Testing
  • Periodic risk assessments and system vulnerability testing (Vulnerability Scanning / Penetration Testing).
  • Adherence to security standards such as the OWASP Top 10.
    • 5. Secure Password Storage
  • Earnex will not store user passwords in Plain Text.
  • Passwords are encrypted (Hashed & Salted) using secure standards such as bcrypt or SHA-256.
    • 6. Data Backup & Recovery
  • The system performs regular data backups and can be restored in case of damage.
  • A Disaster Recovery Plan is in place to quickly restore system functionality in case of unforeseen events.
    • 7. Two-Factor Authentication (2FA)
  • Users can enable Two-Factor Authentication (2FA) to enhance account security.
    • 8. Employee Security Training
  • Employees and relevant personnel receive ongoing training on data security and understanding of PDPA / GDPR.
    • 9. Data Breach Notification
  • In the event of an incident that may lead to a personal data breach, Earnex will notify the data subject within a reasonable timeframe and take immediate remedial action.
    • 11. Policy for Minors
    Earnex prioritizes the safety of young users and recognizes the need to protect the personal data of minors in accordance with applicable laws. The details are as follows:
    1. Service Use Restriction for Minors
  • Earnex's services are intended for users who are at least 18 years of age.
  • Minors under the age of 18 are prohibited from registering for or using Earnex's services under any circumstances.
  • If a registration by a minor is discovered, Earnex reserves the right to terminate the account and delete all data without prior notice.
    • 2. Collection of Minors' Personal Data
  • Earnex does not knowingly collect personal data from minors.
  • If it is discovered that data has been collected from a minor without parental consent, the company will promptly delete the data from its systems upon notification.
    • 3. Notification to Parents/Guardians
  • If a parent or guardian becomes aware that a minor under their care has registered or provided personal information to Earnex, please contact us at support@earnex.ai for investigation and data deletion.
    • 4. User Responsibility
  • All users are responsible for providing accurate information upon registration.
  • If false age information is provided to circumvent restrictions, Earnex will not be liable for any resulting consequences and may suspend the account as appropriate.
    • 5. Policy Changes
  • Earnex may periodically update its policy for minors to align with PDPA, GDPR, or other relevant laws.
    • 12. Policy Updates and Changes
    Earnex reserves the right to amend, update, or change this Privacy Policy at any time without prior notice to ensure it is consistent with legal changes, technology, industry standards, or the company's internal practices.
    In the event of a material change, such as to the purposes of data use, data sharing, or user rights, Earnex will notify you through appropriate channels, such as:
  • Displaying an announcement on the Earnex website.
  • Sending an email to registered users.
  • A notification via the Dashboard system or LINE Official.
    • The updated Privacy Policy will take effect immediately upon its publication on the website, unless otherwise specified.
    Users should review this Privacy Policy periodically to stay informed about the latest information regarding personal data protection and its use by Earnex. Accessing the Earnex website or services after a policy update constitutes your acceptance of the revised terms.
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