Privacy Policy

Eleven Dimensions (“we”, “us”, “our”, or “the Company”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, store, and safeguard personal data when you visit [www.elevendimensions.co.th] (the “Website”), communicate with us, or engage our capital advisory and private credit services. It also describes your rights under the Personal Data Protection Act B.E. 2562 (2019) of Thailand (the “PDPA”).

As a firm engaged in discreet, structured financing, we treat confidentiality and the careful handling of information as fundamental to the trust placed in us. This Policy reflects that commitment.

1. Data Controller
The data controller responsible for your personal data is Eleven Dimensions Limited Company

Address: 263, Soi Phatthanakan 29, Phatthanakan Road, Suan Luang, Bangkok, Thailand 10250

Email: legal@elevendimensions.co.th

2. Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data:

• Identity and contact data: name, title, employer, job role, email address, telephone number, and postal address.

• Professional and financial data: information you provide when enquiring about or engaging our services, including investor or counterparty status, investment preferences, source of funds information, and other details relevant to a prospective or existing engagement.

• Verification and compliance data: identification documents and information we are required to collect to satisfy know-your-customer (KYC), anti-money-laundering (AML), and sanctions-screening obligations.

• Correspondence data: the content of messages, emails, and other communications you exchange with us.

• Technical and usage data: IP address, browser type and version, device information, pages viewed, and other information collected automatically through cookies and similar technologies (see our Cookie Policy).

Sensitive personal data. We do not ordinarily seek sensitive personal data (as defined in Section 26 of the PDPA, such as data on race, religion, health, or criminal records). Where such data is genuinely necessary, we will collect it only with your explicit consent or where otherwise permitted by law.

3. How We Collect Personal Data
We collect personal data when you submit an enquiry or contact form, correspond with us, attend a meeting or call, enter into or negotiate an engagement, are introduced to us by a mutual contact or intermediary, or browse the Website. We may also receive data from public registers, business-information providers, and compliance or screening services where permitted by law.

4. Purposes and Lawful Bases for Processing
Under the PDPA we may only process personal data where we have a lawful basis to do so. We rely on the following bases:

• Performance of, or steps toward, a contract: to respond to your enquiries, evaluate and structure financing, and provide our advisory and private credit services.

• Legal obligation: to comply with applicable laws and regulatory requirements, including KYC, AML, sanctions, tax, and record-keeping obligations.

• Legitimate interests: to operate, secure, and improve the Website and our business, to manage relationships with clients and counterparties, and to prevent fraud — provided such interests are not overridden by your fundamental rights.

• Consent: where required, for certain communications and for non-essential cookies. You may withdraw consent at any time, without affecting processing carried out before withdrawal.

Where we rely on consent and you decline or withdraw it, we may be unable to provide certain services or respond to certain requests.

5. Disclosure of Personal Data
We treat your information as confidential and do not sell it. We may share personal data with:

• our professional advisers (legal, accounting, tax, and audit) and service providers who process data on our behalf under written agreements;

• regulators, courts, law-enforcement, and other authorities where required or permitted by law;

• counterparties, lenders, co-investors, or transaction parties where necessary to progress an engagement and with appropriate confidentiality protections; and

• parties involved in a reorganisation, merger, or transfer of our business, subject to confidentiality.

6. International Transfers
Where we transfer personal data to recipients outside Thailand, we will do so in accordance with Sections 28 and 29 of the PDPA — ensuring the destination has adequate data-protection standards, or putting in place appropriate safeguards, or relying on another lawful exception such as your consent or the necessity of the transfer for the performance of a contract.

7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. Retention periods for compliance records (such as KYC/AML documentation) are set by applicable law. When data is no longer required, we will securely delete, destroy, or anonymise it.

8. Data Security
We maintain appropriate technical and organisational measures to protect personal data against unauthorised or unlawful access, loss, alteration, or disclosure, including access controls, encryption in transit where appropriate, and confidentiality obligations on staff and service providers. No transmission over the internet can be guaranteed to be completely secure, and any transmission is at your own risk.

9. Your Rights Under the PDPA
Subject to the conditions and exceptions in the PDPA, you have the right to:

• be informed about how your personal data is collected, used, and disclosed;

• access and obtain a copy of your personal data;

• rectify inaccurate, out-of-date, incomplete, or misleading data;

• erase or de-identify your data where there is no lawful basis to retain it;

• restrict the processing of your data in certain circumstances;

• object to processing based on legitimate interests or for direct-marketing purposes;

• data portability — to receive your data in a commonly used, machine-readable format and to have it transmitted to another controller where technically feasible;

• withdraw consent at any time where processing is based on consent; and

• lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) in Thailand.

To exercise any of these rights, contact us at legal@elevendimensions.co.th . We will respond within the timeframe required by the PDPA (generally within 30 days). We may need to verify your identity before acting on a request.

10. Cookies
The Website uses cookies and similar technologies. Please see our Cookie Policy for details of the cookies we use and how you can manage your preferences.

11. Third-Party Links
The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their privacy policies.

12. Children
The Website and our services are directed at professional, institutional, and qualified parties and are not intended for individuals under the age of 20. We do not knowingly collect personal data from minors. Where consent of a minor is involved, we will obtain it in accordance with Section 20 of the PDPA.

13. Changes to This Policy
We may update this Privacy Policy from time to time. The current version will always be posted on the Website with its effective date. Material changes will be notified where required by law.

14. Contact Us
If you have questions about this Privacy Policy or how we handle your personal data, please contact us at legal@elevendimensions.co.th