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Privacy Notice

Cars24 Group (Thailand) Co., Ltd.

Cars24 Group (Thailand) Co., Ltd. including its holding company, subsidiaries, affiliates (the “Company”) firmly believes in the highest standards of integrity for Personally Identifiable Information (“PII”) provided by its customers at the time of interaction with the Company, and otherwise.

The Company values its customers’ privacy and is committed to protecting the PII disclosed by customers (“You”, “Your” or “Data Subject”, as applicable) to the Company by any means. The Company is committed to protecting Your PII, in accordance with the Personal Data Protection Act B.E. 2562 (2019) (the “PDPA”) and applicable related regulations thereof which are available on the announcement date of this Privacy Notice.

Please read the following Privacy Notice terms to understand the Company’s practices specifically with regard to how the Company treats Your PII. This Privacy Notice also applies generally to the websites of our parent entity, affiliates, subsidiaries or joint venture entities, which may or may not be referred to in the Website’s content.

1. PII that the Company collects, uses and/or discloses

The Company needs to collect, use and/or disclose Your PII which is necessary to perform administrative activities or transactions of the Company as described in the Section 2 of this Privacy Notice. The Company classifies the categories of PII with examples as follows:

CategoryExamples of PII

Personal Details

    • Name
    • Gender
    • Details with regard to Your vehicle, including but not limited to make, model, identification details of the vehicle, prior use, history, insurance details, registration certificate details, etc.
    • Any other information sought by the Company at the time of Your making an account with the Company, or obtaining a quote from the Company

    Contact Details

      • Address
      • Email address
      • Mobile/ telephone number
      • Any other information sought by the Company at the time of Your making an account with the Company, or obtaining a quote from the Company

      Financial information

        • Income
        • Any other information sought by the Company at the time of Your making an account with the Company, or obtaining a quote from the Company

        Transaction information

          • Information about Your internet connection and mobile device
          • Equipment used by You to browse the Company’s Website
          • Your usage details with regard to the Website
          • Internet Protocol (IP) details / address
          • Your Current Location, Device Location, Device Information and Communication Information to provide customized offerings
          • Computer operating system
          • Preferences and settings such as time zone and language
          • Cookies and Web Beacons
          • Account / User Information
          • Your searches, the results You selected from the search and other activities
          • Your browsing information (browsing length and details of online ads that You clicked on)
          • Your transactional information
          • Any other information sought by the Company at the time of Your making an account with the Company, or obtaining a quote from the Company

          Sensitive PII

            • Religion
            • Criminal record
            • Information relating to health information (blood type, health history, etc.)

            Please note that the following list is only illustrative, and is by no means, exhaustive.

            The Company would like to notify You of the impact in the event that You do not provide the aforementioned PII to the Company. In such event, the Company may not be able to take relevant actions on Your PII which may affect the quality of service or the execution of clerical activities or transactions for You. The Company will ensure that our collection, processing and/or disclosure of Your PII will be limited as necessary under a lawful purpose and basis and compliant with the PDPA and applicable and relevant secondary laws.

            2. The Company’s activity, purpose and lawful basis of collection, use and/or disclosure of Your PII

            Lawful basesActivity/Purpose of collection, use and/or disclosure of PII

            Legal obligation

              • To operate the Company to be consistent with the laws, rules and regulations including court orders or other government agencies that are relevant or applicable to the Company

              Performance of Contact

                • To carry out the Company’s obligations and enforcing rights arising from any contracts entered into between You and the Company, including for billing and collection
                • To carry out the Company’s obligations that arise out of all relevant statutes in relation to Your vehicle, and in relation to Your transactions and interactions with the Company
                • To process and complete Your transactions and make special offers
                • To provide You with notices about Your account
                • To provide You with customer support
                • To allow You to participate in interactive features offered by the Company
                • To process and respond to Your queries
                • To send You communications that You have requested
                • To send You questions that You may be able to answer if You have registered with the Company, or have scheduled an appointment at a Company location or branch
                • To send You information about Your vehicle pursuant to Your visit to a Company branch or location
                • To administer contests and sweepstakes

                Legitimate interest

                  • To protect and improve the services that the Company offers
                  • To enhance the functionality and improve the quality of Your interaction with the Company, and to personalize Your experience while using our services
                  • To generate and review reports and data about, and to conduct research on, the Company userbase and service usage patterns
                  • To make our Website better and easier to use for You
                  • To use and reproduce Your Posts for any purpose
                  • To remove and delete any Post or part of the Post that, in the opinion of the Company, is false, mala fides and misrepresenting
                  • To maintain security and orderliness within the Company
                  • To exercise the rights of the Company and protect the interests of the Company when necessary and lawful, for example, for investigating, preventing and responding to complaints
                  • For internal purposes such as auditing, data analysis and research relating to the Company’s services on the Company’s Website

                  Consent

                    • To collect, use and/or disclose Your sensitive PII
                    • To survey information to develop promotions and product improvements
                    • For marketing promotions, research and programs to help us identify Your preferences, develop programs and improve user experience
                    • To enable and filter advertisements that are relevant to You
                    • To send you promotional emails, phone call, or chat via LINE or other communications
                    • To grant You opportunities to avail special offers/vouchers being offered by third parties to You as a customer of the Company and/or show Your interest in the services of the Company
                    • To share the information, which You have shared on the Company’s Website, with our alliance partners. These alliances / partnerships are done to provide perks and convenience to You. By clicking on the submit button, the Company and the partner will consider You to be an interested user and will use the details submitted by You to contact You and give You a customized experience of the Company / Website services
                    • To send or transfer Your PII overseas which may not have adequate standards of PII protection, only if the law requires that the Company needs Your consent

                    3. Your Consent

                    The Company requests You to carefully read this Privacy Notice and the Website’s Terms of Use under a different tab before You elect to share Your PII with the Company. You also agree that the information furnished by You is lawful, true and correct and does not violate or infringe any laws or any contractual obligations that bind You at the time the information is furnished by You. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence, etc., of the information disclosed by You shall lie on the Company nor will the Company in any way be responsible for verifying any information obtained from You.

                    4. Retention period of PII

                    The Company will retain Your PII on our servers for as long as is reasonably necessary for the purposes listed in this Privacy Notice. In some circumstances, the Company may retain Your PII for longer periods of time, for instance where the Company is required to do so in accordance with any legal, regulatory, tax or accounting requirements.

                    Where Your PII is no longer required, the Company will delete, destroy, pseudonymize, anonymize or make such PII non-personally identifiable information, unless there is a legal obligation or technical reasons whereby the Company may keep Your PII for a longer period of time.

                    5. Disclosure of PII

                    The Company shall be at liberty to disclose, share or transfer Your PII or part thereof to third-party service providers who may facilitate the providing of services, on the Company’s behalf. These service providers have access to Your data only to perform the tasks as stipulated by the Company and are obligated not to disclose or use it for any other purpose. The Company may also share Your PII with third-party vendors, consultants and other service providers who work for the Company, who are bound by contractual obligations to keep Your PII confidential and use it only for the purposes for which the Company discloses, shares or transfers it to them.

                    In addition to the aforesaid, alliance partners / channel partners of the Company may collect Your PII with Your consent from Your mobile device such as device location, device information (including storage, model, installed apps, Wi-Fi and mobile network), transactional and promotional SMS and communication information including contacts to provide customized offerings.

                    6. International transfer of PII

                    The nature of modern business practice is necessary for the Company to transfer Your PII internationally for storage and/or processing in relation to the mentioned purposes in this Privacy Notice. The Company will ensure to have Your PII transferred with appropriate security measures in order to protect Your PII transfer in accordance with the PDPA, which includes the following circumstances:

                    1. To comply with a legal obligation.

                    2. To obtain Your consent and inform You of inadequate PII protection standards of the destination country or international organization which received Your PII.

                    3. To perform the agreement made by You with us or at Your request before entering into an agreement.

                    4. To comply with agreements between us and other parties for Your own interest.

                    5. To prevent or suppress a danger to Your or another person’s life, body or health, and You are incapable of giving consent at such time.

                    6. To carry out activities relating to substantial public interest.

                    7. Public posts

                    As part of our services, You may provide Your reviews, feedback, comments, ratings, photos, etc., on the public groups (Posts). The Company retains an unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, is false, mala fides and misrepresenting. All Posts shall be publicly accessible and visible to all users and, therefore, You should be careful about revealing any sensitive details about Yourself in such Posts. The Company reserves the right to use and reproduce Your Posts for any purpose. Further, the Company may share Your Posts with service providers, businesses or any other third party. If You delete Your Posts from any of the public groups, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by any other user(s) of that public group.

                    8. Use of Cookies on the Website of the Company

                    1. Cookies are text files placed on Your computer that are used to store details of Your internet usage logs or Your visits to the Website.

                    2. The Company uses various types of cookies on its Website, as follows:

                      1. Cookies that are necessarily used for the Website operation process (Strictly Necessary Cookies), in order for the Website to function properly. To delete or prevent this cookie is not possible.

                      2. Cookies that are used to analyze and measure the performance of the Website (Analytical/Performance Cookies). These cookies allow us to recognize and count the number of visitors and to see how visitors move around and use our Website. These cookies are used for web enhancement and optimization purposes and to aggregate statistics on how our visitors reach and browse our Website.

                      3. Cookies used to help remember settings information or the choices You have made on the Company’s website (Functionality Cookies). These are used to enable us to personalize our content for You, tailor the website for Your needs and remember Your preferences, for example, Your choice of language or browsing font size.

                      4. Cookies for advertising (Advertising Cookies). These cookies will remember Your preferences that You used on the website, to tailor advertising to You that is relevant to You.

                    3. Cookies management

                      You can usually choose to set Your browser to remove cookies and to reject cookies, except those used for the purposes of the website system’s operations. If You choose to remove cookies or reject cookies, this could affect certain features of the CARS24 Website/ mobile application.

                    9. Security

                    The Company hereby assures You that the collection and processing of Your PII over the Website is done in a secure and encrypted manner to maintain the safety and privacy of Your PII to prevent the loss, access, use, alteration, amendment or disclosure of PII without authority or due to abuse, for example, by limiting access to PII. The Company further assures you that the Website’s servers and systems have been secured by hosting with AWS, installing anti-virus and anti-malware software and regular security auditing. The Company follows best practices in terms of administration and operations.

                    10. Your rights

                    You have rights to Your PII under the PDPA, and the Company will respect Your rights by taking actions in accordance with any laws, rules or regulations relating to the processing of Your PII. You may exercise the following rights of a Data Subject unless the Company has grounds to lawfully reject Your request:

                    1. Right to withdraw consent – You have the right to withdraw Your consent. The withdrawal of consent will not affect the lawfulness of the collection, use and/or disclosure of Your PII based on Your consent before it was withdrawn.

                    2. Right to access and obtain a copy – You have the right to access and obtain a copy of Your PII that is retained by the Company.

                    3. Right to data portability – You have the right to receive Your PII where the Company can arrange for such PII to be in a readable or commonly used form, by way of automatic tools or equipment or format and can be used or disclosed by automated means. In addition, You have the right to request the Company to send or transfer Your PII to a third party, or to receive Your PII which has been sent or transferred to a third party by the Company.

                    4. Right to object – You have the right to object to the collection, use and/or disclosure of Your PII where the Company proceeds on a legitimate interest basis, or it is for a direct marketing purpose, or for scientific, historical or statistical research purposes.

                    5. Right to erasure – You have the right to request the Company to delete, destroy or anonymize Your Personal Identifiable Information in the event that the Company does not need or has no legal right to keep such Personal Identifiable Information.

                    6. Right to restrict – You have the right to request the Company to restrict the use of Your PII under certain circumstances when there is a pending examination process of the Company in accordance with Your request to rectify Your PII or object to the collection, use and/or disclosure of Your PII, or Your request to restrict the use of Your PII instead of the deletion or destruction of Your PII.

                    7. Right to rectification – You have the right to rectify Your PII that is inaccurate and to update Your PII to not cause any misunderstandings.

                    8. Right to lodge a complaint – You have the right to make a complaint with the Personal Identifiable Information Protection Committee or their office where the Company does not comply with the PDPA.

                    11. How to contact us

                    If You have a privacy concern or question related to this Privacy Notice or would like to exercise Your rights, please feel free to contact us on (between 8 am - 10 pm) or reach out to our customer support at [email protected]

                    12. Third party integration

                    You may access our Website through third-party websites over which the Company has no control. You may optionally provide the Company with information through third-party sign-in services such as Facebook, Pinterest, Twitter, Instagram and Google Plus. In such cases, the Company shall fetch and store whatever information is made available to the Company by You through these sign-in services. Please also note that the Company reserves its rights to use information provided by You, in accordance with the PDPA and the applicable related regulations thereof which are available on the announcement date of this Privacy Notice.

                    Further, it is clarified that during Your usage of our Website, You may see links to third party websites / advertisements / electronic communication service(s), which are provided by third parties. As the operation of third parties is not under control of the Company, the Company does not make any endorsement / guarantee of any service or product offered through third party websites nor make any representation related to any privacy policy or other policies of such third party. Any usage of such third-party website or availing of any service or product through a third party shall be at Your risk and the Company is not responsible for any loss / damage or otherwise. It is recommended that You must study and follow the Privacy Notice displayed on that website separately from the Company’s website.

                    13. Modification of the Privacy Notice

                    The Company reserves the right to amend or modify this Privacy Notice at any time, as and when the need arises. If the Company decides to change this Privacy Notice, the Company will post the updated version on this page and/or update the modification date below. We request You to regularly check this Privacy Notice from time to time to keep You updated about changes made. Your continued use of the services provided by the Company after any changes, shall be deemed to be Your acceptance of such changes.

                    This Privacy Notice was issued on was last updated on 18th May, 2021 (Version 1.0).