EVme Plus Company Limited (“EVme”, “we”, “us”, and/or “our”) recognizes the importance of protecting your Personal Data for you, (1) an electric vehicle renter (2) any individual who related to electric vehicle renter or (3) prospective individual who join our marketing campaign/activities or (4) any individual who interested in our products or services from any channels or (5) subscriber through various online and any media, as the case may be (6) any individual whose Personal Data we have obtained (e.g. a driver or passenger) (collectively referred to as “you”). We know that you care about how information about you is collected, used, disclosed, and/or cross-border transferred. We shall announce the following privacy notice for your acknowledgement;
This privacy notice (“Privacy Notice”) applies to our business, mobile applications, websites, call center, social networking sites, online communication channels, and other channels where we collect your Personal Data. However, please read this Privacy Notice in conjunction with the terms and conditions of the particular service that you use.
For the purpose of this Privacy Notice,
“Personal Data” means any information relating to an identified or identifiable natural person (no matter it can be identified by itself, or together with other information) and
“Sensitive Data” means racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life, criminal record, health record, handicap information, labor union membership, genetic data, biometric data, or any sensitive data that may impact the data subject as provided by Personal Data Protection Act B.E.2019
“Data Processing” means any processing of personal data and/or sensitive data such collecting, recording, copying, organizing, keeping, updating, modifying, using, recovering, disclosing, forwarding, transferring, merging, deleting, destroying, etc.
We reserve the right to review or modify this Privacy Notice from time to time to be aligned with our services, your suggestion and your comment including to comply with the relevant law, regulation, procedure, guideline. We will either notify or send a notice to you regarding the change of this Privacy Notice on our website so please review it periodically. Any changes to this Privacy Notice will immediately become effective when we post the revised Privacy Notice on our website or application.
1. Types of Personal Data we collect
We may collect or obtain the following types of information, which may include your Personal Data, directly or indirectly from you or other sources or through our group legal entities, our affiliates and subsidiaries, our service providers or business partners depending on the context of your interactions with us, and the services you need or want from us. The Personal Data we may collect, use, disclose and/or cross-border transfer may include, but is not limited to, the following:
- 1. Personal details, such as your title, full name, gender, nationality, age, date of birth, photograph, know-your-customer (KYC) information, signature, CCTV records, Dashcam records, vehicle tracking information (e.g. driving behavior and locations), complaints, claims, comments, and inquiries on our services, and your communication records with us;
- 2. Contact details, such as postal address, delivery details, billing address, telephone number, mobile phone number, email address, social media account (e.g. LINE ID, Facebook account), Google account, Apple ID account, and other contact details via electronic channels;
- 3. Information for identity verification from official identification documents, such as national identification number, passport number, driving license or any similar identifiers;
- 4. Transaction details, such as payment information (e.g. purchasing history, purchasing amount, behavior on the purchase and/or use of our services including to payment history), booking details and electric vehicle rental contract details (e.g. selected plan, delivery and pickup date, time and location), insurance details, and other details of services purchased;
- 5. Financial details, such as service price, fees, payment method, number and information of credit card, bank account numbers and types, and other services registration information;
- 6. Vehicle related services information, such as license plate number, vehicle identification number (VIN), chassis number, model, model year, year of manufacture, engine size, standard auto parts, vehicle maintenance history, distance, seating capacity, battery capacity and status, vehicle charging type, power and period, electrical system functionality, gear conditions, issues or any other information of your vehicle;
- 7. Profile details, such as account identifiers, and username and password;
- 8. Behavior details , such as information about user’s behavior through the use of our services;
- 9. Technical Information, such as Internet Protocol (IP) address, web beacon, log, device ID, GPS location, device model and type, network, connection details, access details, Single Sign On (SSO) access information, access time, time spent on our page, cookies, login data, search history, browsing details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access the platform; and/or
- 10. Sensitive Data, such as Sensitive Data from official identification documents (e.g. religion on national identification card or race on passport).
If you provide the Personal Data of any third party (e.g. employer, shareholders, directors or relevant person to your organization (in case of corporate customer)), you must ensure that you have the rights and/or authority to provide such person`‘`s Personal Data and authorize us to use such Personal Data in accordance with this Privacy Notice. Also, you must be responsible to notify each person of this Privacy Notice and/or obtain consent from each person (if necessary) and/or rely on other legal bases.
We will not collect the Personal Data of minors (who have not yet become sui juris, i.e. under 20 years of age or have not reached legal age through marriage as applicable by law), quasi-incompetent persons, and incompetent persons, and do not allow such persons to register for the use/purchase of our products, goods, and services without obtaining consent or without relying on any other legal bases. In the event we do not know that data subject is minor, incompetent person or quasi- incompetent person which we have unintentionally collected Personal Data from such persons without consent, we will delete it immediately, and may need to cease providing service to such persons, unless we may rely on other legal bases apart from consent.
2. Purposes and legal bases on which we rely on to collect, use or disclose your Personal Data
We respect your privacy and are committed to protecting your personal data and your sensitive data. We realize that you as a customer wish to receive the security of using our services. We will collect, use, and disclose (“processing”) to perform the following lawful purposes:
1. The purposes on which we rely on consent to collect, use, or disclose your Personal Data:
- 1. Marketing and Communications: To provide marketing, aadvertising, marketing campaign, data analytic, communications, sales, special offers, promotions, notices, news, and information about the products and services from us, our affiliates, our group legal entities and subsidiaries, service provider and/or business partners which we cannot rely on other legal bases;
- 2. Data Analytics Services : To conduct data analytics services, develop marketing channel, launch new promotions, promote our campaigns, provide the best aggressive marketing strategies;
- 3. Cross-border transfer: To evaluate the overall risk management, personal data shall be transferred to our group entities, affiliated and subsidiary companies and/or business partner, service provider outside Thailand.
- 4. Sensitive Data : The purposes to collect, use, disclose, and/or cross-border transfer your Sensitive Data are listed below:
- 1. Criminal record such as to verify the accuracy and completion of your information; to assess your suitability and qualifications; and to conduct background examining and screening on you
- 2. Sensitive Data from official identification documents (e.g. religion on national identification card or race on passport): To authenticate and verify identity
We may collect, use, and/or disclose your Personal Data on the legal basis of contractual basis, for starting or entering into a contract or for performance of a contract with you as listed of activities below:
- 1. Providing the services to you: such as to register and enable the use of our services either in writing or electronic, including the electric vehicle subscription service; to enable the use of our mobile application; to manage your service user account; to respond to your requests before entering into a contract; to execute a contract with you and to manage our contractual relationship included period of test-driving; to issue quotations as you request; to facilitate and perform other activities related to our services; to complete and manage bookings and to carry out financial transactions related to payment, refund, reimbursement, issuance of bills, receipts, and invoices; to proceed and monitor delivery, replacement, return, cancel or exchange of our services; to coordinate with our business partner or service provider for provision of related services, including call center and insurance; to monitor, examine, seize and track the vehicles; and to provide emergency assistance and aftersales services;
- 2. Registration and authentication: such as to register, verify, identify and authenticate your identity;
- 3. Relationship management: such as to process and update your Personal Data as our service user and to store relevant documents referring to you; to handle customer service, call center and/or hotline-related queries, requests, feedback, complaints, claims, disputes or indemnity; to provide technical assistance and deal with technical issues; and to facilitate the use of our services;
3. The purposes on which we rely on legal obligation, for fulfilment of our legal obligations to collect, use and disclose your Personal Data
- 1. Complying with applicable legal and regulatory obligations: such as to comply with legal obligations, legal proceedings, or government authorities’ orders, which can include orders from government authorities outside Thailand, and/or to cooperate with courts, regulators, government authorities, and law enforcement bodies when we reasonably believe we are legally required to do so. We may need to disclose your Personal Data to strictly comply with said legal obligations, legal proceedings, or government authorities’ orders, including to comply with internal investigations procedures, complaints or claims, interrogation, crimes or fraud prevention, and/or to establish legal claims.
4. The purposes on which we rely on legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties to collect, use and disclose your Personal Data
- 1. Profiling and data analytics: such as to learn more about the products, goods and services you receive and other products, goods, and services you may be interested in receiving, for instance by looking at the types of products, goods and services that you use from us, how you like to be contacted; to conduct service satisfaction survey for us, to collect information from your use of our goods or services, to undertake statistics, behaviour analysis, customer segmentation based on group of products, time span, customer’s location, market trends, for promotional purposes, new campaigns, to know better about you, to resolve issues with our existing products, goods and services; and to improve our business operation;
- 2. To improve business operations, products, and services: such as to evaluate, manage, improve, research and develop the services provided to you; to conduct statistic reports, trends and plans, or any other activities in a similar manner; to resolve issues with our existing services; to improve our business operation, quality, safety, and security of our services, and to develop new products and services;
- 3. Information technology management: such as for the purpose of our business management; to communicate internally within our organization, including to manage IT operations, communication systems, and IT security systems of the organization, including system access control and records, monitoring of system, equipment and internet system;
- 4. Functioning of our websites, mobile application, and platform: such as to administer, operate, track, monitor, and manage our websites, mobile applications and platforms to facilitate and ensure that they function properly, efficiently, and securely; to facilitate your experience on our websites, mobile applications and platforms; improve layout, and content of our websites, mobile applications, and platforms;
- 5. Protecting our interests: such as to audit control purpose, to identify, evaluate, and prioritize of risks (risk management), to protect the security and integrity of our business; to exercise our rights or protect our interest, where it is necessary and lawful to do so, for example to detect, prevent, and proceed against any fraud claims, intellectual property infringement claims, or violations of law; to manage and prevent loss of our assets and property; to secure the compliance of our terms and conditions; to comply with our policies; to detect and prevent misconduct within our premises which includes the use of CCTV; to follow up on incidents; to prevent and report crimes and to protect the security and integrity of our business;
Failure to provide Personal Data to us may affect you and we may be unable to respond to your request or to perform a contract. As a result, we may not be able to offer or provide you our services, whether partially or in whole. We may not be able to facilitate or may not be able to comply with our obligations under your contract and you may suffer from damages or miss out on opportunities in certain circumstances. In some instances, this may affect responsibility for legal obligations that we or you are required to comply with, this may lead to relevant penalties as applicable.
We do not intentionally collect, use or disclose your Sensitive Data (e.g. religion on nationality) from official identification documents for other above purpose. However, in case that we will collect, use, and/or disclose your Sensitive Data, we will seek your explicit consent from time to time, or rely on other legal basis as permitted by law.
2. The purposes on which we rely on contractual basis to collect, use and disclose your Personal Data
3. Who might we disclose or transfer your Personal Data with?
We may disclose or transfer your Personal Data to the following third parties who collect, use and disclose Personal Data in accordance with the purposes under this Privacy Notice. We recommend you visit their privacy policies to learn more details on how they collect, use and disclose your Personal Data as you may also be subject to their privacy policies.
- 1. Our group entities, affiliates and subsidiariesTo conform with the electric vehicle rental contract or electric vehicle test-driving agreement or other necessary purposes as specified above. We may need to disclose or transfer your Personal Data to our group entities, affiliated and subsidiary companies, including but not limited to, Arun Plus Co. Ltd., or otherwise allow access to such Personal Data by our group entities, affiliated and subsidiary companies for the purposes set out in this Privacy Notice.
- 2. Our service providers เราอาจว่าจ้างบริษัทอื่น We may use other companies, agents or contractors to perform services on behalf of or to assist with the provision of products and services to you. We may share your Personal Data to our service providers or third-party suppliers including, but not limited to: (1) payment and payment system service providers; (2) digital signature service providers; (3) logistic and courier service providers; (4) vehicle tracking service providers; (5) call center service providers; (6) mobile application developer, infrastructure, internet and IT service providers; (7) identity verification and anti-fraud screening service providers; (8) data storage and cloud service providers; and/or (9) marketing, advertising media and communications agencies.
In the course of providing such services, the service providers may have access to your Personal Data. However, we will process your personal data to be lawful, fairness and in a transparent manner in relation to specific and necessary purposes.
- 3. Our business partner or service provider We may disclose and/or transfer your Personal Data to companies that we have partnered with to offer or enhance products and services, for example, insurance partners, hotel partners, banking and financial institution partners and other platform service providers. However, the Personal Data disclosed or transferred in this manner will be subject to these business partners’ privacy policies, not this Privacy Notice.
- 4. Third parties required by law In certain circumstances, we may be required to disclose and/or transfer your Personal Data to government agencies, courts, officers, government authorities, law enforcement bodies or other third parties where we reasonably believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.
- 5. Assignee of rights and/or obligations In the event of any reorganization, merger, business transfer, whether in whole or in part, sale, purchase, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or similar transaction; the assignee of our rights and/or obligations will comply with this Privacy Notice to respect your Personal Data.
- 6. Other third parties We may be required to disclose Personal Data based on the legal grounds in accordance with the purpose as specified in this Privacy Notice to other third parties, such as complainants or other third parties that we receive a request to access our CCTV records as the case may be.
4. International transfer of your Personal Data
In any cases, we may need to transfer Personal data abroad for the services providing purpose to you. Subject to contractual obligations between us and other legal entities or our legal obligations such as collecting or processing personal data on Cloud with a platform or server located abroad (e.g., Singapore or the United States, etc.) to support information technology systems located outside Thailand. Some of the recipients we may share your Personal Data with may be located outside Thailand. The destination countries may or may not have the same equivalent level of protection for Personal Data protection standards. In such case, we ensure appropriate safeguards are in place, and oblige the recipients to protect your Personal Data in accordance with this Privacy Notice and as allowed by applicable laws using appropriate security measures. We will request your consent where consent to cross-border transfer is required by law.
5. Retention of your Personal Data
Subject to applicable data laws, we will retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory, and internal requirements. We reserve our right to process and disclose your Personal Data and your Sensitive Data Processor and any relevant authorities as required by laws, whichever the case may be, within the following timeline:
|Basic for Processing||Period of Processing|
|Electric vehicle rental Contract Electric vehicle test-driving Agreement||10 years from the expiration date of Electric vehicle rental Contract or Electric vehicle test-driving Memorandum|
|Legitimate Interest||10 years from the expiration date of Electric vehicle rental Contract|
|Consent given for Electric vehicle rental Contract||10 years from the expiration date of Electric vehicle rental Contract|
|Consent NOT relating to Electric vehicle rental Contract||10 years from the date of consent given or whenever data subject withdraws his/her consent.|
In the event we refuse to enter into an electric vehicle rental contract or electric vehicle test-driving Agreement where you are the person involved. We have the right to process your personal data and sensitive data or disclose the information to the processor and relevant governmental officers, authorities within 10 years from date rejection in the electric vehicle rental contract or an agreement to test drive electric vehicles or for as long as necessary for processing.
6. Your rights as a data subject
Subject to applicable laws and exceptions thereof, you reserve the right to check the personal data types of information or sensitive data. Furthermore you may have the following rights to:
- 1. Request access to your Personal Data. You may have the right to access or obtain a copy of your Personal Data we collect, use or disclose about you;
- 2. Request to rectify . You may ask us to have any inaccurate, outdated, incomplete, and misleading Personal Data that we collect, use or disclose about you rectified;
- 3. Request to port . You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are collecting, using, or disclosing your Personal Data on the basis of your consent or to perform our contract with you. However, if exercise of your rights violates the rights and freedoms of others or we must use your Personal Data to perform a task carried out in the public interest, or for compliance with the law, we have the discretion to reject your request;
- 4. Request to object . You may have the right to object to the collection, use and disclosure of your Personal Data for certain cases as required by the applicable laws;
- 5. Request to restrict . You may have the right to suspend use of your Personal Data in certain cases;
- 6. Request to withdraw your consent . You can withdraw your consent at any time where we collect, use and disclose your Personal Data based on your consent in certain cases;
- 7. Request to delete. You may have the right to ask us to delete, destroy or anonymize your Personal Data that we collect, use, or disclose, except where the retention of such Personal Data is for compliance with a legal obligation or to establish, exercise, or defend legal claims; and
- 8. Lodge a complaint You may have the right to lodge a complaint to the competent authority where you believe that we do not comply with applicable data protection laws.
If we process your personal data and/or sensitive data based on contractual basis or legitimate interest. We reserve the right to reject your rights under (3) and (4) has been exercised
We respect your decision to withdraw consent. However, we would like to inform you that there are restricted on the right to withdraw consent by legal basis or contractual basis. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If we reject your requested, we will provide you with a record of rejection with reasons
7. Security Measures
We have implemented access control measures which are secure and suitable for our collection, use and disclosure of Personal Data. We restrict access to Personal Data, as well as storage and processing equipment, by imposing access rights or permission, user access management to permit access to authorized personnel, and user responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of Personal Data, or theft of device used to store and process Personal Data. This includes methods enabling the re-examination in relation to access, alteration, erasure, or transfer of Personal Data which are in accordance with methods and channels to collect, use or disclose Personal Data.