Privacy Policy

Effective Date: December 1, 2020

EFH Privacy Policy

Welcome to, operated by EQUITIES FIRST HOLDINGS (“EFH,” “we,” “us,” “our”).  This Privacy Policy covers our website (, content, software products, mobile applications, mobile and web-based services, or any other EFH materials or services that refer to this policy (collectively, the “Site”). This Privacy Policy is intended to help you understand how we collect and use the personal and confidential information you decide to share or provide through use of the Services.  This Privacy Policy sets forth our privacy practices and the possible uses of the information that we gather via the Site.This Privacy Policy applies to the Site, regardless of the medium in which it is accessed (e.g., mobile browser, computer browser, etc.). 




This Privacy Policy applies to your use of the Site, regardless of the medium by which the Site is accessed by you.

The Information We Collect

When you visit the Site and use any of the services provided via the Site, we may collect information as disclosed below.

Personal Information: We collect personal information to provide the information or services requested by an individual. “Personal information” refers to any information relating to an identified or identifiable individual who is the subject of the information. For example, when you provide us with certain personal information, it may include your name, your email address, your telephone number, your address, and any other personal or preference information that you provide to us.

Sensitive Personal Information. We may also collect and use sensitive personal information such as data relating to your commission or alleged commission of offences, and your biometric identifiers, including but not limited to facial recognition, retina recognition, fingerprint recognition, voice recognition for the purpose of verifying and confirming your identity for the use of our products and services. If we collect, use, maintain or disclose your sensitive personal information, we will ask for your explicit consent.

Usage Information. When you use and navigate the Site, we may collect additional information from you that may not by itself reasonably identify you as the source (collectively, “Usage Information”).  Usage Information may include information regarding your mobile telephone, your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the Site, or the areas of the Site you visited and the actions you performed on the Site.(Unless otherwise specified, Personal Information, Sensitive Personal Information, and Usage Information will collectively be referred to as “Personal Data”.)

How We Collect Information

Directly from You. We collect Personal Information from you when you voluntarily provide Personal Information to us by, for example, by completing various forms, or requests for information.

Through Your Use of the Site. We record Usage Information that your browser transmits when you visit our Site. We also collect Usage Information about how you access and interact with the Site through the use of automated tracking technology, such as “cookies” and “web beacons.” A cookie is a small data file that is transferred to a web browser, which enables our Site to remember and customize your subsequent visit. Most Internet browsers automatically accept cookies. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from our Site. Please refer to your Internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Site may be limited, and you may not be able to participate in several of the Site’ features. Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.

Other Technologies: When you use the Site, or when you contact us, we may also collect other information about you as disclosed below. This information may be gathered for all Site users.

    – We may collect certain information from your activity using other tracking technologies like tags, pixels, clear pixels, gifs, bugs, beacons, and other similar technologies, some of which may enable EFH or our service providers to identify you and collect information about you across devices and Site.
    – We may collect information about your interactions with our customer service, such as the date, time and reason for contacting us, feedback you share with us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.

How We Use Personal Data

We collect, process, use or disclose your Personal Data to carry out the purposes below:

  • Provision of the Site: The Site is a medium for interaction between you and us. We use and share the information we collect from you for the purposes described below. If you use our Site, we use your information to process and respond to your applications, requests, comments, inquiries, and other forms you submit through the Site.

  • Improving our Site: We use your information to enhance our understanding of our users’ preferences and improve our Site accordingly.

  • Service Providers: We may employ third party service providers to perform functions on our behalf. They may have access to personal information needed to perform their functions but may not use it for other purposes.

  • Legal Obligations: From time to time, we may be required to share personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or related to an alleged unlawful activity.

  • Protection of EFH and Others: We may release your information when we believe release is appropriate to comply with the law or any rule, regulation, government or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of EFH, our affiliated companies, our users, or others. However, this does not include selling, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the terms set forth in this Privacy Policy.

  • Sale or Acquisition: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if EFH is transferred to another company, we may disclose and/or transfer your information as part of the transaction. If the surviving entity is not EFH, your information may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.

  • Other Legitimate Interests: We will use and disclose your Personal Data when necessary for our legitimate interests, as long as such interests are not overridden by our users’ interests, rights, and freedoms with respect to their Personal Data.

In addition to the above, we may also collect, process, use or disclose your Personal Data without your prior consent based on the legal grounds below:

  • When such action is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such contract;
  • For preparing historical documents or archives for public and education interest, or for purposes relating to research or statistics;
  • For prevention or suppression of danger to a person’s life, body or health; and
  • For the necessary completion of our tasks in the public interest.

To Whom May We Disclose Your Personal Data

We may disclose your personal data to the following parties:

  • Our group companies, business partners and/or other persons that we have a legal relationship with, including our directors, employees, third party contractors, authorized representatives, and advisors;
  • Governmental authorities and/or supervisory or regulatory authorities, including the Bank of Thailand, the Securities and Exchange Commission, and the Ministry of Digital Economy and Society, and any credit bureau, fraud prevention agencies, courts, authorities or any persons whom we are required or permitted by laws, regulations, or orders to share Personal Data; and
  • Our suppliers, agents and other entities where the disclosure of your Personal Data has a specific purpose and is done under a lawful basis, including third parties providing services to us, such as for market analysis, benchmarking, and security service purposes;
  • Any relevant persons as a result of activities relating to selling rights of claims and/or assets, restructuring or acquisition of any of our entities, where we may transfer their rights to, and any persons with whom we are required to share data for a proposed sale, reorganization, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
  • Banks, financial institutions and third parties where required by law, such as to help recover misdirected funds or to trace funds where you are a victim of suspected financial crime; and
  • Attorneys, authorized persons or legal representatives who have lawfully authorized power.

How Long Do We Retain Your Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal requirements. The period we keep your Personal Data will be linked to the prescription period or the period under the relevant laws and regulations which we are subject both in Thailand and in other countries.

Your Rights to Your Personal Data

You can exercise your rights relating to your Personal Data below:

  • 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.
  • Right to access and obtain copy: You have the right to access and obtain copy of your Personal Data held by us, or to request the disclosure of details on how your Personal Data was acquired, unless we are entitled to reject your request under applicable laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.
  • Right to data portability: You have the right to receive your Personal Data where we have arranged such Personal Data in a format which is readable or commonly used by ways of automatic tools or equipment, and which can be used or disclosed by automated means. You also have the right to request us to send or transfer your Personal Data to a third party, or to receive your Personal Data which we have sent or transferred to a third party, unless it is impossible for us to do so because of the technical circumstances, or if we are entitled to lawfully reject your request.
  • Right to object: You have the right to object to the collection, use or disclosure of your Personal Data at any time where such Personal Data was collected, used, or disclosed on a lawful basis, or for the purpose of direct marketing, or for the purpose of scientific, historical or statistic research, unless we have legitimate grounds to reject your request according to applicable laws.
  • Right to erasure: You have the right to request us to delete, destroy or anonymize your Personal Data, unless we have legitimate grounds to reject your request according to applicable laws.
  • Right to restrict: You have the right to request us to restrict the use of your Personal Data under certain circumstances, such as when we are processing your request to rectify your Personal Data.
  • Right to rectification: You have the right to rectify your inaccurate Personal Data and to update your incomplete Personal Data.
  • Right to lodge a complaint: You have the right to make a complaint with the Personal Data Protection Committee in the event that we do not comply with applicable laws.


We take reasonable physical, technical and organizational precautions to protect your Personal Data that is either available from or collected by this Site.  We have taken steps designed to safeguard the Site’s integrity, its telecommunications, and computing infrastructure, including but not limited to, access control and management, authentication, monitoring, auditing, and encryption measures according to applicable laws.  Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be completely secure.  As a result, we cannot ensure or warrant that your Personal Data will be completely secure from misappropriation by hackers, nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network, unless such breach arises from our negligent act or omission.


This Site may contain links to or information about other websites that are outside our control or custody.  We are not responsible for the content or privacy practices of other websites and suggest you review their privacy statements to understand how your information is used or shared by those other websites.  We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within a page of our Site.


This Privacy Policy was last modified on the date first printed above.

We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in our business practices.  If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy Statement on the Site.  Changes to the Privacy Policy will become effective and will apply to the Personal Data collected starting on the date we post the revised Privacy Policy on the Site.  Your continued use of the Site after any change has become effective will constitute your acceptance of any change. 

Other Provisions

Additional Terms. This Privacy Policy may be supplemented by other terms and conditions with respect to your personal information. For example, if you reside in a particular country, there may be policies specifically applicable to you (see below). This Privacy Policy will supplement any other privacy statements provided by EFH, or its subsidiaries, affiliates, and the like.

Do Not Track. Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Site does not respond to “Do Not Track” signals.

Children Under 20. We do not market to and do not knowingly collect any Personal Data from or about a child under the age of 20 without the consent of the child’s parent or legal guardian.  If we discover that we have inadvertently collected Personal Data from a child under the age of 20, we shall delete such Personal Data immediately.

Comments and Questions

If you have a comment or question about the collection, usage and/or disclosure of your Personal Data as well as a request to exercise your rights under this Privacy Policy, please contact us and/or our Data Protection Officer at the contact information listed below:

Equities First Holdings

10 West Market Street

Suite 3050

Indianapolis, IN 46204


Data Protection Officer: 

Julie LaPoint


OFFICE  317-429-3500

DIRECT 317-250-0200


10 West Market Street, Suite 3050

Indianapolis, IN  46204  United States


Privacy Policies Applicable to Specific Jurisdictions

Your jurisdiction may have specific requirements with respect to how EFH and its subsidiaries treat your Personal Data.  For EFH’s full privacy policies in certain jurisdictions, please use the links below:

Hong Kong Privacy Policy

Singapore Privacy Policy

UK Privacy Policy