Privacy Policy

This Privacy Policy Statement (the “Policy”) covers APD Mobile banking (hereinafter referred to as “APD Mobile” services provided by Asia-Pacific Development Bank Plc. (hereinafter referred to as “APD Bank” or “The Bank”. This Statement describes how the Bank collects, uses, retains, discloses and secures Customer/Authorized User’s data in relation to APD Mobile. Customer/Authorized User data includes but is not limited to Customer/Authorized User’s personal information, transaction(s), financial condition(s), and accounts and/or cards linked to APD Mobile Banking.


APD Bank/ The Bank


Asia-Pacific Development Bank Plc. and includes the Head Office or any other branches of the Bank including its successors and assigns.

Customer/Authorized User


Customer/Authorized User who register for the APD Mobile Banking Services.

Customer Data/ Personal Information


Any data/ information about the Customer/Authorized User provided in the Application and obtained by the Bank in relation to usage of the Mobile Banking Services.

Mobile Banking/

Mobile Application


A software application downloaded and installed on Customer/Authorized User’s smartphone device or other electronic devices in order to access Mobile Banking Services.



Any service provided under the Mobile Banking offered by the Bank, as amended from time to time.

1.    Data Collection and Usage

The Bank collects certain Customer/Authorized User personal data for various purposes including but not limit to the following:

  • To process the Customer/Authorized User’s application, to provide instructions and to conduct transactions pertaining to services offered by the Bank;
  • To introduce Customer/Authorized User to the Bank’s products and/or services by communicating to Customer/Authorized User and sending Customer/Authorized User the information and marketing materials about the products and/or services;
  • To serve for system development, maintenance, support and testing;
  • To perform credit assessment, risk management, and other operational and business purposes;
  • To serve legal purpose such as protecting and enforcing the rights of the Bank, resolving any dispute/claim/demand, preventing and/or investigating any illegal action, unauthorized transaction or access to Customers’ account or card, fraud or crime that may occur or has been committed, suspected or alleged; and
  • TO comply with applicable legal and regulatory requirements, whether national or international, court orders and other public requirements now or hereafter enacted.

The Customer/Authorized User data and information required from Customer/Authorized User includes but not limited to the following:

  • Customer/Authorized User's name, address, e-mail address, telephone number, age, gender;
  • particulars of identity documents such as identity card or passport;
  • where applicable, financial information such as information of income, sources of income, assets, liabilities, account information, account balance, payment records; and
  • in the case of a corporate Customer/Authorized User, the names and particulars of the authorized officers, directors, shareholders, country of incorporation and such financial information of the company as the Bank shall require from time to time.

To ensure that the Bank maintains accurate and updated personal Customer/Authorized User's information, the Customer/Authorized User is advised to furnish timely, accurate and complete information pertaining to his or her instructions to the Bank. System will update Customer/Authorized User’s records upon the receipt of Customer/Authorized User’s information from time to time.

2.    Data Disclosure

In compliance with Cambodia's Law and Regulations Applicable to Bank and Financial Institutions, Customer/Authorized User data is handled confidentially and will not be disclosed to any third party or external organization except:

  • where such disclosure is required by law, Court Order or is otherwise legally permitted;
  • where it is required the National Bank of Cambodia or other regulators, law enforcement bodies, courts, government authorities, credit reporting company or agency.
  • Customer/Authorized User’s legal representative, authorized agents, and/or administrator;
  • any subsidiary, affiliate, branch and office of the Bank;
  • Other banks and financial institutions as well as other parties as necessary in order for the Bank to provide Customer/Authorized User with service and/or product;
  • where requested or permitted by the Customer/Authorized User in writing

3.    Data Retention and Management

The Bank records and maintains any data and information Customer/Authorized User has provided, modified and/or deleted on Mobile Banking. In the event that Customer/Authorized User uninstall or remove application from his/her device or discontinue using Mobile Banking, we still retain some of his/her information to comply with our internal policies, guidelines and relevant laws governing data retention and management.

4.    Data Security

To ensure Customer/Authorized User data and information is secure, the Bank takes physical and electronic measures, i.e. the encrypted user PIN and two-step verification and two-factor authentication on PIN where possible. All connections with APD Mobile Banking will follow industry standard Transport Layer Security (TLS). However, the Bank does not fully guarantee that Customer/Authorized data cannot be accessed, disclosed, altered or deleted under various circumstances including but not limited to hardware or software failure or unauthorized use. Customer/Authorized User acknowledges and agrees that they provide information to Bank at their own risk.

5.    How Users Can Revoke Consent

In the event that the Customer/Authorized User loses possession/control of his/her mobile phone(s)/device(s) on which the Software and/or the Authentication Credentials are installed and on which the Customer/Authorized User receives Mobile Notifications, the Customer/Authorized User must immediately notify and instruct the Bank in writing to revoke the Authentication Credentials and discontinue Mobile Banking Services.

Any Instructions received by the Bank prior to receipt of such written notification associated with the Customer’s/Authorized User’s Security Code shall be deemed to have come from the Customer/Authorized User and the Bank shall be entitled to rely on such Instructions. Whether the instructions actually originated from the Customer/Authorized User or not, this will be indemnified from any security breach. The Customer/Authorized User shall be liable to the Bank for any kind of unauthorized or unlawful use of any of the above mentioned Authentication Credentials or of the Mobile Banking Services or any fraudulent or erroneous instruction given and any financial charges or liabilities thus incurred shall be payable by the Customer/Authorized User and not by the Bank.

6.    Change and Update

To comply with applicable laws and/or conform to changes in our internal policies or business, the Bank may, from time to time, revise or update the Policy. When Customer/Authorized User accesses to APD Mobile Banking after the Policy is amended, the Customer/Authorized User is deemed to have accepted the revised or amended terms and conditions of the Mobile Banking.


The Mobile Banking Privacy Policy Statement shall be governed by the applicable law of Cambodia as applied by the competent courts of Cambodia as applicable from time to time. The Bank and the Customer/Authorized User hereby irrevocably submits to the exclusive jurisdiction of the courts in Cambodia to hear and determine any suit, action or proceeding and to settle any disputes, which may arise out of or in connection with the Mobile Banking Statement and terms and conditions.

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