Notification of V2X Company Limited

No. 000/2022

Personal Data Protection Policy

V2X Company Limited (“V2X”, “Company” or “of Company”) recognizes the importance of protecting your personal information. (as defined below) in this Privacy Policy (the “Policy”) describes the collection, use, disclosure and/or overseas transfer of your personal data obtained from various sources; Your rights and practices regarding such information

1.) About the company

   The Company is the data controller that collects, uses and discloses your personal information.

   The company is a legal entity incorporated under the laws of Thailand. Its head office is located at 183 Regent House Building, 18th Floor, Ratchadamri Road, Lumpini, Pathumwan, Bangkok 10330.

2.) How to contact the company

  If you would like more information or want to exercise your rights under this policy, you can contact the company.

By email to the company at : [email protected]

By phone, contact the company at 02 078 5558 (Customer Call Center business hours: Monday – Friday 8.30 – 17.00)

By mail to V2X Company Limited (Head Office) No. 183 Regent House Building, 18th Floor, Ratchadamri Road, Lumpini, Pathumwan, Bangkok 10330

3.) What is personal data?

   “Personal Data” means any information about an individual. which allows the person to be identified whether directly or indirectly but does not include information of the deceased in particular

“Sensitive Personal Data” is the following: race, ethnicity, political opinions. cult religion or philosophy sexual behavior criminal record Health information, disability such as congenital diseases, vaccinations, medical certificates union information Genetic data, biological data such as fingerprints, face models, iris data, etc.

4.) What personal data is collected?

4.1) The personal information the company collects depends on your relationship with the company. and the services or products you want from the company Personal information about you that the Company may collect, use, disclose and/or transfer to foreign countries. including but not limited to the following types of personal data:

(a) personal details such as title, first name, last name, gender, age, occupation, job title, work position, education, nationality, date of birth, marital status; Information on government-issued cards (for example, identity card number passport number Tax Identification Number product driving license information, etc.), signature, sound recording Recording of telephone conversations, photographs, video surveillance, house registration and other identity information.

(b) contact details such as address, telephone number fax number Location data, email address, LINE ID, Facebook account, Instagram ID and other IDs from social networking sites.

(c) Product details such as serial numbers Product, license plate number, car maker, car model, year, color, engine number, car body number, product type, Mileage in kilometers, battery, battery voltage, fuel level, brake wear, Location and movement information (eg time, location, speed), product insurance details Details of accessories such as transceiver, SIM card, details of information received from using the service, GPS data and product location. and other product-related information such as maintenance information. and repair information, etc.

(d) transaction details such as payment details date and/or time of payment Amount of payment, method of payment, details about refund, registration, interest, installment and number of installments. Service request form, purchase order form, receipt, recipient’s signature Receipts, invoices, transactions, transaction history, transaction status and other details of the services or products you have purchased.

(e) Marketing and communication details, such as your choice to receive marketing information from the Company. Affiliates, partners and your communication options

(f) profile details such as service account Username or Application Username (eg V2X-A2), details of the Company’s service and product history, photos, contact history. complaint history Your interests, needs, feedback and responses to the satisfaction questionnaire.

(g) Technical details such as Internet Protocol (IP) address, browser type and version. Your browsing behavior and patterns, cookies, device ID, device model and device type. duration and place of access

4.2) Providing personal information of other persons such as name, surname, address details and telephone numbers for emergency contacts to the company or family members using your car You must ensure that you have the authority to do so and that the Company is legally permitted to use their personal data in accordance with this Policy. This is to those individuals for their acknowledgment and/or consent. (or use other legal bases as an exception to consent) to deliver such information to the Company in accordance with this Policy.

4.3) The Company will not use sensitive personal data such as race, ethnicity, political opinions. cult religion or philosophy sexual behavior Criminal records, health information, disability, trade union information Genetic data, biological data, etc., except in cases where the law allows the company to do so. or when you have given your express consent

  You must ensure that all personal information provided is complete, accurate and true.

5.) Methods for receiving and collecting personal data

  The Company may receive and collect your personal information in the following ways:

    (a) Personal Information You Provide to the Company: You may provide your Personal Information directly to the Company. There will be when you contact the company for information. Fill out the online form or fill out the paperwork. Subscribing for membership or registering for receiving or requesting information on products, services or benefits from the Company or when you express your opinion back to the Company

    (b) Personal Data We Automatically Collect From You: The Company may collect certain technical information about your device. Your browsing behavior and patterns This is personal information stored by cookies (Cookies) and other similar technologies, which the Company will notify you before use.

(c) Personal Information Obtained From Third Parties: From time to time, the Company receives personal information about you from others, such as affiliates. product dealer Company service provider or business partners of the company If those companies are permitted to disclose your personal information to them in accordance with their privacy policies. and/or which you have previously given consent to disclose information to such persons, as the case may be.

6.) Purpose and legal base for collecting, using and disclosing personal data

    The Company collects, uses and discloses personal information for the following purposes. (collectively referred to as “objective”)

   (a) to provide you with products and services: to manage Enter into a contract and perform the duties of the company according to the contract. or any obligations the Company has with you or the organization you represent, such as a trial product delivery Compliance with contracts for sale of products Payment related services This includes verification, confirmation and cancellation of transactions. Product Warranty Insurance negotiations and other services related to insurance Registration of services related to other products and services after sales service to locate your product, to provide you with services such as emergency services; Facilitation and troubleshooting services with background checks and product information. To process payments for use of the Services, issue receipts, outstanding amounts, invoices and proof of purchase, to provide benefits. including providing other services as required by the Company and its distributors as a service provider or received a request from you, etc.

(b) Registration and Verification: To perform verification and verification of your identity. To register and receive various services from the company

(c) to improve business operations Products and Services: To assess, analyze, manage, improve, conduct research, plan, conduct surveys and statistical analyzes. to develop the system The quality and safety of the company’s products and services, such as satisfaction with the product. Satisfaction with the sale of the product or the service provided by the product distributor To assess the effectiveness of the company’s products, digital media and marketing campaigns. Consumption patterns and trends, behavior, etc., including information about your preferences and interests in the Company’s products or services. or to create aggregated and anonymous reports. to know the problem and how to fix it or for employee training and employee performance appraisals to improve business products and services.

(d) to manage relationships with you: to communicate with you about the products and services you receive from the Company; affiliates product dealer Company service provider or from the company’s business partners To notify you, including notification of renewal To process and update your information as a member of the Company To provide information about the products you use Provide travel reports and check status and product information. to maintain relationship with the company’s customers To facilitate your use of products and services for the implementation of assistance, coordination, listening to opinions or responding to inquiries related to the Company’s products and services.

(e) Marketing and Communications: for information sharing Public relations, communication and promotion of the Company’s products or services and/or product dealer Company service providers, partner companies, to send you invitation letters to attend company events through the Company’s contact channels and/or product dealer Service providers of the Company, business partners, such as websites, e-mail, telephone, fax, postal, SMS, MMS or social media, etc.

(f) Information Technology Management: To manage Information Technology Operations communication system management Information technology security maintenance and inspection and information technology security audits Business management for compliance, policies, and internal processes.

(g) Legal Compliance: To comply with the laws, regulations, rules, orders, requirements and legal obligations of the Company.

(h) Risk: For risk management, performance monitoring. and assess the risks

(i) Protecting Company Interests: For security purposes such as photography and video recording. To exercise Company rights and protect Company interests when necessary and lawful, for example to detect, prevent and respond to complaints. to manage and prevent loss of property To detect and prevent wrongdoing within the company’s premises or computer system

(j) Fraud Detection: To prove your identity. to ensure compliance with other laws and regulations (eg to comply with anti-money laundering rules; and prevent fraud) including internal audits and records. property management Fraud databases, systems and other business controls

(k) Corporate transactions: in the event of a sale, transfer, merger, reorganization or other similar cases As part of doing so, the Company may transmit or transfer your information to one or more third parties.

(l) Life: To prevent or suppress harm to the life, body or health of a person.

6.2) The Company collects, uses, discloses and/or transfers your personal data under any legal basis or basis. one of the following

(a) to comply with the laws to which the Company is subject;

(b) to perform the contract you or the organization you represent as a party to the Company or to act upon your request prior to entering into that contract

(c) It is necessary for the legitimate interests of the Company and of third parties.

(d) to prevent or suppress a danger to the life, body or health of a person;

(e) for the public interest for carrying out missions in the public interest or the exercise of the rights of government officials

(f) where your consent is required for certain activities in connection with the collection, use or disclosure of your personal data. The company will ask for your consent before using your personal information.

6.3) Where the Company may use your personal information for other operations not specified above The company will give you a notice to know more. It will indicate the information used in connection with such operations and will seek your consent in the event that your consent is required.

6.4) In the event that the Company has a need to collect personal information from you in order to comply with a law or contract, or it is necessary to provide personal information to enter into a contract Then you cannot provide personal information to the Company upon request. The Company may not be able to perform the above related purposes.

7.) Disclosure of personal information

7.1) The Company may disclose your personal information to third parties who collect it. Use or disclose personal information For the purposes of this Policy, you can read the privacy policies of those third parties to learn more about how such third parties collect them. use or disclose your personal information You, too, fall under those separate privacy policies.

7.2) The Company may disclose your personal data for the purposes to the following third parties:

(a) as the Company may need to transfer your personal data to its affiliates; and/or partners business partner

(b) Service Providers of the Company: The Company may share your personal information with third-party service providers or suppliers to provide services on behalf of the Company or to assist in providing products and services to

(c) Business partners of the Company: both domestically and internationally, such as financial institutions business retail business telecommunication business Restaurant businesses, etc., where the Company may jointly offer or offer products or services to you.

(d) Third parties as required by law: In some cases, the Company may be required to disclose or share your personal data in order to comply with the law. This includes complying with law enforcement agencies, courts, officials, government agencies or other third parties where the Company believes it is necessary to comply with a legal or regulatory obligation. or to protect the rights of the company rights of others or for the safety of persons or to investigate, prevent, or deal with fraud issues or in terms of security or safety

(e) Counselors: This includes attorneys. technician and auditors who assist in the company’s business operations. and exercise legal claims and fight legal claims

(f) Assignee of rights and/or duties: in the case of business reorganization merger All or part transfers of business, sales, purchases, joint ventures, grants, transfers, or all or part of the business, assets or shares, or other similar transactions.

7.3) The Company may disclose your personal information to third parties where required or permitted by law. Therefore, if the law requires your consent The company will ask for your consent first.

8.) Transfer and protection of personal data

8.1) Because the company Your personal information may be transferred or transmitted between affiliated companies. and/or partners, partners, for the collection, use and disclosure of personal information under the above purposes To allow you to access the services of the company to provide customer care to make decisions about improving the service for content development or for other purposes specified in this policy

8.2) When transferring your personal data to affiliates and/or partners, partners, the Company will comply with the laws relating to your personal information. Including the company will comply with security measures to ensure that there is an adequate level of protection for your personal information. and the company will ensure that The overseas transferee will protect your personal data with a standard of protection equivalent to the protection under Thai law, if necessary.

8.3) In the event that the Company has a necessity to transfer your personal data to a foreign country If the Company finds that the standards of personal data protection in foreign countries are insufficient in accordance with the regulations on personal data protection announced by the Commission The Company will obtain your consent or rely on other relevant legal bases permissible for the transfer of your personal data outside of Thailand.

9.) Storage period

9.1) The Company will keep personal data for as long as necessary. To carry out the purposes set out in this policy. and in accordance with the Company’s duties under the law After your personal data is no longer necessary or legal to keep. The company will delete or destroy that personal information. without notifying you

9.2) The retention period may vary depending on the purpose for which the personal data is collected. In the event that personal data is used for a short period of time, for example for a specific task marketing activities or for the purpose of recruiting personnel The Company may delete or destroy such information after the expiration of such period.

9.3) You have the right to have the Company delete, destroy or in some cases make personal data that does not identify you. Unless the company is required to keep your personal information in accordance with the law.

10.) Youth Privacy Policy

  The Company’s products, services and websites do not have a goal or purpose for collecting personal information from youths, including quasi-incompetent persons. and incompetent persons

  In the event that the owner of the personal data is a minor who has not reached the age of majority by marriage or has no status as a person who has reached the age of majority under Section 19, Section 20 or Section 27 of the Civil and Commercial Code To obtain consent from the subject of such personal data, proceed as follows:

(a) where the consent of the minor is not in which the minor may give consent; alone as provided in Section 22, Section 23 or Section 24 of the Civil and Commercial Code Must obtain the consent of the person exercising parental power to act on behalf of the minor.

(b) in the case where the minor is not over ten years old to obtain consent from the person exercising parental power to act on behalf of the minor

  In the event that the owner of the personal data is an incompetent person Requesting consent from the subject of such personal data Ask for consent from the guardian who has the power to act on behalf of the incompetent person. In the event that the owner of the personal data is a quasi-incompetent person Requesting consent from the subject of such personal data to obtain consent from a guardian who has the power to act on behalf of a quasi-incompetent person.

11.) Distributor of V2X products

  Companies and distributors are separate legal entities and each have their own privacy policies. If you have questions about the dealer’s privacy practices, please contact us. including if you do not wish to receive notifications For any publicity, communication, and promotion of a Distributor’s products or services not related to V2X, please contact the Distributor directly.

  When you buy a product from a dealer The dealer will disclose your personal information to the company. The Distributor and Company are separate entities and you should read the Distributor’s Privacy Policy to ensure that you understand the Distributor’s privacy practices and practices. In addition, as dealers are generally your first means of contact. Distributors are therefore the ones who can give you answers about personal data protection practices. fully relevant personal In addition, information about the duty to protect personal information has been provided to the distributors, but the company is not responsible for compliance with the relevant laws of the distributors.

12.) Rights to your personal data

  You have the following rights in relation to your personal data in the Company’s possession. If you wish to apply for the right You can contact the company as detailed in the topic. “How to contact the company” above.

12.1) Right of access

    You may request access to or obtain details of the personal data you have provided to the Company, except for refusal by law or a court order, or access to or obtaining such details will have an effect that may cause damage to the Company. rights and freedoms of others

12.2) Right to correct information

    You have the right to request rectification of your personal data if personal data about you in the Company’s possession is inaccurate or incomplete.

12.3) Right to request deletion or destruction of data

    You have the right to ask the company to remove or destroy. or make your personal information non-identifiable In the following cases

(a) Personal data that is no longer necessary for the purposes for which it was collected or used.

(b) personal data for which you have revoked your consent for the Company to keep, use and disclose and have been reviewed by the Company. There is no legal ground for the Company to be able to collect or use it any longer.

(c) the personal data that you have objected to the company from collecting or using it anymore and the Company cannot reject an objection request based on applicable legal exceptions.

(d) Personal information that you object to the collection, use or disclosure of your personal information for direct marketing purposes.

(e) the personal data is illegally collected, used and disclosed

You have the right to request the erasure or destruction of the personal information you have provided above. Except for exceptions made by law, for example, the collection of personal data is necessary for the purposes of the performance of a contract. or for the purpose of establishing legal claims, complying with, exercising legal claims or raised to fight legal claims or other purposes as required by law.

12.4) Right to Restrict Use

    You have the right to ask the company to suspend the use of your personal data in the following cases.

(a) You have asked the Company to correct your personal data to be accurate, current, complete and that the Company is in the process of reviewing your request.

(b) you have requested to suspend the use of information the Company may have collected, used or disclosed inappropriately. instead of deleting or destroying such personal data

(c) The Company no longer needs to collect your personal data for the purpose of collecting it. But you need to ask the company to keep it in order to establish a legal claim. Compliance or exercise of legal claims or raising the defense of legal claims for your benefit

(d) you object to the collection, use or disclosure of your personal data in the interests of or for public interest. or the use of state power or legitimate interests and the company is in the process of reviewing your request.

(e) you have objected to the collection, use or disclosure of your personal data on the basis of or citing scientific research; history or statistics (if applicable) and the Company is in the process of reviewing your request.

12.5) Right to object

    You have the right to object to the collection, use or disclosure of personal information. In the following cases

(a) It is an action for the legitimate benefit of the Company or that of another person.

(b) is an action for the public interest or the use of state powers given to the company

(c) in the event that the Company collects, uses or discloses your personal information for direct marketing purposes

(d) is carried out for the purposes of scientific research studies; History or statistics (if applicable)

    If you exercise your right to object to the collection, use or disclosure of such personal data You have the right to request that the Company delete or further restrict the use of your personal data.

12.6) Right to Transfer

     You have the right to obtain your personal information collected by the company. by requesting the Company to transmit such data to you in electronic form or by an automated means, unless such transfer request cannot be made under the limitations of the Company’s means.

12.7) Right to withdraw consent

    You have the right to withdraw your consent to the collection, use or disclosure. If in the case that you have previously given consent to the company unless there is a restriction on the right to withdraw consent by law or the performance of contractual obligations of the Company that is beneficial to you, provided that your withdrawal of consent will not affect Collecting, using or disclosing personal information that you have given your consent to.

12.8) Right to complain

    You have the right to complain about the collection, use and disclosure of personal information. In the event that the company violates or fails to comply with the law You can file a complaint through the company’s contact channels. And you may file a complaint to the Personal Data Protection Committee.

However, the Company may deny the exercise of the above-mentioned rights of the personal data subject in accordance with the rules prescribed by the Company without contrary to the law.

The Company will provide a channel for the owner of personal data to contact the Company in accordance with Clause 2) in order to submit a request for action in accordance with the above rights. In the event that the company Reject the above request, the company will inform the reason for the refusal to the owner of the personal data.

The owner of the personal data has the right to lodge a complaint with the Personal Data Protection Committee in the event that the Company personal data processors, employees or contractors of the Company Violates or fails to comply with the Personal Data Protection Act B.E. 2562 or announcements issued under the said Act.

13.) Amendments to this Policy

13.1) The Company may amend the Policy. This is from time to time in order to comply with the changing use of your personal information. and to comply with applicable law The company will notify you of the changed policy through the company’s contact channels.

13.2) The Company will use the latest version of this Policy to refer to the methods for collecting, using and disclosing your personal information.

This Policy is effective June 1, 2022 and supersedes all prior privacy policies established by the Company.

Announced on 25 May 2022

(                                              )