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Phone: +66817672163
E-mail: info@centuno.net

DATA PROTECTION AND PRIVACY NOTICE

This Data Protection and Privacy Notice explains how Centuno (referred to as "we," "our," or "us") collects, processes, stores, and protects your personal data when you visit our website at https://centuno.net or use our services. We are committed to safeguarding your privacy and complying with applicable data protection laws, including the Personal Data Protection Act (PDPA) of Thailand.
By accessing our website or using our services, you acknowledge and agree to the terms outlined in this Privacy Notice.

HOW TO CONTACT US
If you have questions, concerns, or requests regarding your personal data or this Privacy Notice, please contact us:
📧 Email: info@centuno.net
📍 Address: No.34 CP Tower 3, 4th Floor, Phaya Thai Road, Thung Phaya Thai Sub-district, Ratchathewi District, Bangkok Metropolis, Thailand
📞 Phone: +66817672163

PERSONAL DATA WE COLLECT
We may collect the following types of personal data:
  • Information you provide directly: This includes your name, date of birth, address, email, phone number, payment details, and government-issued identification.
  • Information collected automatically: When you visit our website, we may collect technical data such as your IP address, browser type, and browsing behavior.
  • Information from third parties: We may obtain data from public sources or third-party services, such as identity verification providers, to comply with legal requirements like anti-money laundering (AML) regulations.

HOW WE USE YOUR DATA
We process your personal data for the following purposes:
  • Providing services: To fulfill contractual obligations, such as processing subscriptions or service requests.
  • Legal compliance: To meet regulatory requirements, including fraud prevention and tax reporting.
  • Marketing: To send you promotional materials, provided you have consented to such communications.
  • Improving our services: To analyze website usage and enhance user experience.

YOUR DATA PROTECTION RIGHTS
You have the following rights regarding your personal data:
  • Access: Request a copy of the personal data we hold about you.
  • Rectification: Correct any inaccurate or incomplete data.
  • Erasure: Request the deletion of your data under certain conditions.
  • Restriction: Limit how we process your data in specific circumstances.
  • Portability: Receive your data in a structured, commonly used format.
  • Objection: Object to the processing of your data for direct marketing or other purposes.
  • Lodge a complaint: File a complaint with the relevant data protection authority.

DATA SHARING
We may share your personal data with:
  • Payment processors and banks: To facilitate transactions.
  • Regulatory authorities: To comply with legal obligations.
  • Third-party service providers: Such as IT support, marketing agencies, and legal advisors, under strict confidentiality agreements.
We do not sell your personal data to third parties.

DATA SECURITY
We implement technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse. These measures include encryption, access controls, and regular security audits.

DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with legal obligations. Once the data is no longer needed, it will be securely deleted or anonymized.

UPDATES TO THIS POLICY
  • We may update this Privacy Notice from time to time. Any changes will be posted on our website, and we will notify you if significant updates require your attention.
Data
  • Full name.
  • Date of birth.
  • Address.
  • Email address.
  • Phone number.
  • Government-issued ID details.
  • Tax identification number, tax status.
  • Payment details.
  • Technical data (IP address, login, preferences).
  • our requests, preferences, feedback, and other information collected when you communicate with Centuno.
Legal bases
data

Purpose

• Necessary for the performance of a contract, such as a subscription or service request to use Centuno products/services.
• Necessary for compliance with laws, including, among others, anti-money laundering laws and service supervision.
  • Consent, in the case of responding to interest forms for using Centuno products/services, including marketing that directly affects the data subject's privacy rights, such as direct marketing.
  • Full name.
  • Email address.
  • Phone number.
  • Cookies.
  • Your requests.
  • Information you provide to Centuno.
Marketing activities
Purpose
Use of Centuno products/services and compliance with laws and regulations
Your Data Protection Rights

You have the following rights regarding your personal data:


  • Right of access to your data – You have the right to ask us if we are processing your personal data, why we are doing so, under what legal basis, the categories of data we process, who we share your data with, how long we retain it, and to request a copy of the data we are processing. If you cannot find sufficient information in our Privacy Policy, please contact us.
  • Right to object to certain processing – Direct marketing or processing of certain data.
  • Right to have your data deleted – Also known as the "right to be forgotten." You can exercise this right if you withdraw your consent and there is no further legitimate interest or legal basis for processing your data, if your objection to processing under legitimate interests outweighs our interests, if the processing is no longer necessary, if a law requires the data to be deleted, or if the processing is unlawful.
  • Right to restrict processing – If the personal data we process is inaccurate, if our processing is unlawful, if the data is no longer necessary for the original purpose of processing but needs to be retained for potential legal claims, or if you have objected to processing carried out under legitimate interests and we are still determining whether there is an overriding need to continue processing.
  • Right to data portability – You can request your data that we process using a computer, which you provided to us based on consent or because it was necessary for a contract.
  • Right to ask about automated decision-making – You have the right to ask us to explain the logic involved in any automated decisions and for the decision to be reviewed by a human if it affects your rights or freedoms.
  • Right to rectification – If any of your personal data we hold is inaccurate, you can request to have it corrected.
  • Right to lodge a complaint – You have the right to lodge a complaint with the competent data protection authority if you have concerns about how we process your personal data. However, we would appreciate it if you contacted us first and gave us an opportunity to resolve the issue.


Personal Data of Children and Minors

We do not knowingly collect, process, store, use, or disclose the personal data of individuals who do not have sufficient legal capacity to perform work and/or provide services under the laws of their country of citizenship and/or permanent residence, unless permitted by applicable laws.

You must not use Centuno services if:

  1. You do not have sufficient legal capacity to use Centuno services in accordance with the national laws of your country of citizenship and/or permanent residence; or
  2. You have not obtained all necessary permissions and consents to perform work and/or provide services in the country of which you are a citizen and/or in which you permanently reside and/or from which you access and/or plan to use Centuno services.


Cookies

Please refer to the Centuno Cookie Policy to learn about the types of cookies we use, for what purposes, and how you can manage your cookies.

WHEN AND HOW WE SHARE INFORMATION WITH OTHERS
To provide you with certain features and services, we must share your personal data with partners, external third-party service providers, related entities, and regulatory authorities. They process your personal data based on data processing agreements and according to strict instructions, which do not allow them to use your data for any other purposes without notifying you or obtaining your consent. The categories of parties we may share your data with include:
  • Payment service providers and banks (to fulfill payment obligations);
  • KYC/KYB/AML service providers (for due diligence purposes and to comply with applicable laws);
  • Third parties taking legal actions related to debt collection on our behalf (in accordance with applicable laws);
  • Our legal, accounting, and auditing service providers, government authorities, authorized bodies, and law enforcement agencies.

Additionally, we may disclose your personal data to third parties if: (1) you request or authorize it; (2) to address emergencies or acts of God as provided by law; and (3) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.


SECURITY OF YOUR INFORMATION
To help protect the privacy of personal data you transmit when accessing and using our services, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to employees who need to know that information to provide services to you.

Marketing Communications

We may use some of your personal data to determine which products, services, special features, and offers from Centuno may be of interest to you. You may receive marketing emails and text messages (marketing communications) from Centuno if you have requested information from Centuno and/or agreed to receive marketing communications from Centuno, or if you are a registered user of Centuno services and have not opted out of receiving such communications.

You can ask us to stop sending you marketing communications at any time by following the opt-out instructions contained in our marketing email or message sent to you (if available). You can also let us know directly that you prefer not to receive any marketing communications from Centuno by emailing info@centuno.net

DATA STORAGE AND RETENTION
We retain your personal data for as long as necessary to achieve the purpose for which it was collected, usually for the duration of our contractual relationship plus any period thereafter as required or permitted by law, or to satisfy any legal obligations. When the data is no longer required, it will be deleted.

CHANGES AND UPDATES TO THE PRIVACY POLICY
We may change this Privacy Policy from time to time. When we make updates, changes, or revisions, they will be effective when we post the updated Privacy Policy on our Website. We will notify you and provide you with an opportunity to review this Privacy Policy before you choose to continue using our Website.