PRIVACY POLICY
Effective Date: October 25, 2024 Release Date: October 25, 2024 RIDDARA Automotive (Thailand) Co., Ltd. (hereinafter referred to as "RIDDARA" or "we") is committed to protecting and respecting your personal data. This privacy policy (hereinafter referred to as "this policy") describes how we will collect, use, and disclose your personal data in accordance with the Personal Data Protection Act B.E 2562(2019) ("PDPA"), how to contact us, and your rights related to personal data processing. Please read this policy carefully and learn in detail how we collect and use your personal data so that you can better understand our products and/or services and make appropriate choices.
I. Personal Data We May Collect, Use, and Disclose
1.1 The personal data we collect depends on your relationship with us and the products and/or services you receive from us. We may collect, use, disclose, and/or transfer abroad the following types of personal data, including but not limited to:
(1) Personal detailed information: We may collect your Personal Data such as your first name, last name, gender, age, hobbies, occupation, identification information (such as ID card, passport, driver's license, etc.), and communication information during the customer service liaison process.
(2) Account and Contact Information: We may collect your account and contact information such as your RIDDARA ID, phone number, email address, verification code, basic personal account information (such as username, profile picture), location information, LINE, Facebook, Instagram, and/or other social media accounts and/or ID.
(3) Vehicle Information: We may collect your vehicle information such as vehicle identification number(VIN), license plate number, brand, model, year, color, vehicle type, vehicle status, lock or unlock status, horn, vehicle lights, vehicle windows, air conditioning, mileage, battery voltage, tire pressure, electricity consumption per 100 km, driving information (such as time, speed), vehicle charging and discharging status information, after-sales vehicle maintenance record, vehicle insurance details, modification/decoration details, additional equipment information (such as signal transmission equipment, SIM card), charging service usage, and other vehicle-related data.
(4) Transaction and Financial Information: We may collect information relating to transactions between you and us, including your financial information such as payment details, payment date or time, payment amount, payment method, refund request, interest, down payment, installment payment and details of installment payment, date and place of purchase of products or services, voucher information, order information, and other financial information.
(5) Marketing and Communication Information: We may collect information relating to marketing, communications and prospect customer information such as the marketing information you receive from us, our affiliated companies, and partners, and information about your participation in marketing activities, including your name, contact information, vehicle purchase plan, interested vehicle model, current vehicle information, visit records, test drive information, source channel, and other personal data related to your participation in marketing activities, use of products and services, and communication information.
(6) Historical Information: We may collect historical information during your use of our products and/or services, such as your user account, login name or application username, historical records during the use of our products and/or services, contact history, complaint history, your requests, feedback, and satisfaction survey results.
(7) Technical Information: We may collect technical information during your use of our products and/or services, such as Internet Protocol (IP) address, cookie information usage, device code, device model and device type, usage duration, and access services.
1.2 We may collect, use, disclose your personal data and/or transfer it to third parties, inside and outside of Thailand, when you use our products and/or services according to the function as follows:
(1) When you use RIDDARA products, websites and application programs
When you register and use a personal account through RIDDARA products, websites, and application programs, you need to provide your phone number, email address, verification code, user name, user nickname, user avatar, vehicle identification number (VIN)and other information you voluntarily provide, so that we can help you set up and manage your account.
When you use the RIDDARA products, websites, and application programs, we automatically collect technical data about your use of the related products, websites, and application programs in order to monitor their functionality and take troubleshooting actions if necessary. To do this, we use information such as your access IP, device information (such as phone manufacturer name/phone brand/phone model/master board name/device name/system version), general vehicle information (such as vehicle make, model, year, color), and usage data (such as number of clicks, views, and potential issues or errors).
(2) Test-drive appointment
When you apply for a test drive appointment service, we will collect your appointment store, name, mobile phone number, region, and intended model so that we can contact you further and arrange for a suitable dealer to provide you with a test drive service. In addition, we will collect the location of your mobile device (if you allow) so that you can use the map function in the RIDDARA App and display your location relative to nearby outlets or sales stores on the map to recommend suitable nearby appointment stores for you.
(3) Remote Vehicle Services
We willcollect your email account, vehicle identification number (VIN) and your vehicle data. We use this information to provide remote vehicle services so that you can receive vehicle related information straight to your RIDDARA APP, including vehicle status, remaining battery and estimated endurance range, tire pressure, power consumption per 100 km, average vehicle speed and other information. In addition, you can also remotely control certain functions of your vehicle through the APP, such as locking/unlocking the doors, locating the vehicle (blinking lights, honking the horn), raising and lowering windows (if there is a sunroof), air conditioning and temperature regulation, battery charging and discharging, and other services related to vehicle control. We also use this information to send you service push notifications in your RIDDARA APP to inform you of upcoming maintenance and service reminders for your vehicle.
(4) Charging map
To help you easily find nearby charging stations, we have embedded Google Maps H5 in the RIDDARA APP. You can also choose to directly jump to the Google Maps APP (if it is installed on your device) to view nearby charging stations and use the navigation function. When you use the charging map or navigation function, your location information will be directly collected by Google LLC. Please carefully review the third party's privacy policy before using their services.
(5) Maintenance Appointment
You can schedule vehicle maintenance and repair services through the RIDDARA APP. When you book a vehicle maintenance service, we need to collect your name, contact information, location information, and vehicle information to register your appointment and recommend suitable after-sales service stores.
(6) Customer service response
When you use customer service or other user response functions (including: service consultation, filing complaints, and requests), we need to collect your contact information (the phone number you use to contact us/or other contact information you voluntarily provide to us) and your communication information with us, so that we can verify the issue and help you resolve it.
(7) Marketing
We may send you advertisements or other marketing information about our products and services via email, text message, websites and applications. You can choose to stop receiving marketing information from us at any time by sending an email to riddara.th.privacy@geely.com or by clicking the "unsubscribe" button in the marketing emails we send you.
1.3 We will receive and collect your personal data from the following sources:
(1) Personal data collected directly from you: when you contact us, fill out online or paper forms to collect personal data, register or provide information to receive products, services, or certain benefits, and when you provide us with feedback, you may directly provide us with your personal data.
(2) Personal data collected automatically: we may automatically collect technical information related to your device, including your behavior and search patterns. This personal data is stored by cookies and other similar technologies. Before use, we will inform you and request your consent.
(3) Personal data from third parties: sometimes we receive your personal data from third-party sources other than yourself, such as our affiliated companies, vehicle dealers, our service providers, or our partner companies. Provided that such sources have the legal right to disclose your personal data. If you have ever consented to disclose information to a third party, we recommend that you read the privacy policy of that third party to ensure you understand their protection guidelines and practices regarding personal data.
II. The purposes and legal basis for collecting, using, and disclosing personal data
2.1 The purposes for which we collect, use, and disclose personal data are as follows:
(1) Registration and identity verification, to verify your identity when you register and receive our various services.
(2) Provide you with products and services, such as communicating with you about the products and services you receive, offering you vehicle-related services, vehicle management, and vehicle status monitoring (telematics system) services, product warranty, after-sales service, emergency assistance services, and services related to insurance, loans, and other services provided by us, our vehicle dealers, service providers, or partner companies, as well as addressing your inquiries, feedback, and complaint handling requests.
(3) Fulfill our contract obligations with you or the organization you represent, or to carry out pre-contract procedures at your request, such as test drives, vehicle transactions, vehicle delivery, product warranty, after-sales service, etc.
(4) Comply with the law, in order to adhere to laws, regulations, guidelines, orders, provisions, and our statutory responsibilities.
(5) Marketing and communication: to release news, market, and promote our products or services, we may send you marketing information that may interest you or invite you to participate in our events through the website, email, phone, fax, SMS, multimedia messages, or social media.
(6) Managing technical security monitoring and protection: to ensure the security of products, websites, and applications, we monitor network security and data, including preventing unauthorized access to our computers and other electronic communication systems, and preventing files related to the installation and updating of malware (malware distribution).
(7) Improving business, products, and services: for evaluation, analysis, improvement, research, planning, survey, and statistical analysis to enhance the quality and security of our products and services, such as market research, product satisfaction survey, satisfaction evaluation of sales products or vehicle dealer services, and marketing campaign effectiveness analysis, thereby improving our business, products, and services according to market trends and consumer demand.
2.2 We will collect, use, disclose, and/or transfer your personal data based on any of the following legal grounds
(1) To comply with the laws and regulations to which we are subject.
(2) To fulfill the contract between you or the organization you represent and us, or to carry out pre-contractual procedures at your request.
(3) For the purpose of legitimate interests, which are legally enjoyed by us or a third party.
(4) To prevent or suppress dangers to personal life, health, or security.
(5) To prepare historical documents or archives for public interest or for purposes related to research or statistics.
(6) In certain cases where your consent is required for activities related to the collection, use, or disclosure of your personal data, we will seek your consent before processing your personal data.
(7) In accordance with the public interest or the exercise of official authority granted.
When you read and agree to this policy, you understand and acknowledge that we collect, use, disclose, or process your personal data for the purposes specified in this policy and in compliance with applicable laws.
III. How we share your personal data
We may share data with our affiliated companies, third-party service providers, dealers, and certain business partners to operate our business, maintain our relationship with you, and provide you with products and services. For example, we share personal data in the following circumstances.
• Within our group, this includes our parent company, affiliates, subsidiaries, business units and other companies under common ownership who provide the services to you on our behalf.
• Dealer partner, we may share personal data with our dealer partners so that they can further contact you and provide you with requested services or products, such as responding to your request for a quote, scheduling service appointments, and performing vehicle diagnostic, maintenance and repair services. Please note that we and our dealer partners are separate legal entities with separate privacy policies. Each dealer operates as a separate legal entity, and when you communicate with them, you should read their privacy policies to understand how they collect, use and disclose your personal data.
• Service provider, we may share personal data with third party service providers or suppliers to provide services on our behalf or to assist in the provision of products and services as well as offering products or services to you such as telematics service providers, cloud service providers, technology and software providers and other service providers as necessary to provide services, perform contractual or legal obligations.
When third parties have access to your personal data, we will take the necessary contractual, technical and organizational measures to ensure that your personal data is treated securely.
IV. International transfer of personal data
As an international company, we share your personal data with our group companies, subcontractors and business partners around the world. Specifically, we transfer personal data to South Korea (where our telematics service provider is located) to provide telematics services and data hosting services; and to Singapore (where our cloud service provider is located) to provide IT support and data hosting services.
Where such transfer of your personal data occurs, we will take actions and measures to ensure that your personal data is transferred securely and that the recipient has an adequate level of protection standards as required by the PDPA or other applicable laws. If the destination country does not have an adequate standard of data protection, we will ensure that the transfer of your personal data is in compliance with the PDPA or other applicable laws, including for the grounds set out in Section 28 of the PDPA, as follows:
(a) fulfilling a legal obligation;
(b) when you have been informed of the inadequate standards of data protection in the destination country and your consent has been obtained;
(c) comply with any agreement between you and us or any request you make prior to entering into any agreement;
(d) for your benefit, to comply with our agreements with other parties;
(e) to prevent or suppress a danger to the life, body or health of you or another person where you are incapable of giving consent; or
(f) carrying out activities related to major public interests.
V. Your data protection rights
You have specific legal rights in relation to the personal data we process about you.
• Right of access, you have the right to request a copy of the personal data we are processing about you, which we will provide to you in electronic form. For your privacy and security, we may ask you to prove your identity before providing the requested information.
• Right to rectification, you have the right to request that we correct incomplete or inaccurate personal data we hold about you.
• Right to erasure, you have the right to request that we erase the personal data we process about you, unless we need to retain such data to comply with a legal obligation, or to establish, exercise or defend legal claims.
• Right to object, when the legal basis for our processing of your personal data is our legitimate interests, you have the right to object to such processing on grounds related to your personal situation. We will comply with your request unless we have an overriding legitimate interest in the processing which outweighs your interests and rights, or we need to continue processing the data to comply with a legal obligation .
• Withdraw consent, if you have given us your consent to process your personal data, you have the right to withdraw your consent at any time and free of charge. This includes where you wish to opt-out of receiving marketing communications from us. You can unsubscribe at any time by following the instructions at the bottom of the emails you receive. The lawfulness of processing your personal data before you withdraw your consent remains unaffected.
• Right to restriction, you have the right to restrict our processing of your personal data where you believe such data is inaccurate, our processing is unlawful or we no longer need to process such data for a particular purpose, but because we are unable to delete the data due to legal or other obligations or because you do not want us to erase it.
• Portability, you have the right to obtain the personal data we hold about you in a structured electronic format and to transmit such data to another data controller where: (a) it is personal data you have provided to us, and (b) we are processing that data on the basis of your consent (e.g. for direct marketing communications) or for the performance of a contract with you.
and other rights granted by applicable laws and regulations regarding personal data protection. We will protect your legitimate rights and interests in accordance with applicable laws. After receiving your rights request, we may verify your identity, and we will process your rights request or give you feedback as soon as possible. For further details on how to make any of these requests regarding your personal data, please see the "How to contact us" section of this privacy policy.
If you have concerns about how we use your personal data, you also have the right to lodge a complaint with your local data protection authority. However, we would appreciate it if you first contact us directly with your concerns so that we can try to resolve them together. You can find our contact information below.
VI. How to contact us?
If you have any questions about how we use your personal data, you can contact us via email: riddara.th.privacy@geely.com.
VII. Update on Privacy Policy
We have been developing our products and services and will review and update this policy accordingly. Therefore, we encourage you to revisit this policy periodically. The date at the top of this policy lets you know when it was last updated. Unless otherwise stated, this privacy policy applies to all services we provide to you and all personal data we process in the course of our services. We will strictly abide by the provisions of the privacy policy. We will not make any material changes to our privacy policy or practices that would reduce the level of protection of personal data without your consent.