1.Definitions
The definitions in this privacy policy (the “Privacy Policy”) shall be as follows:
“You” means the user of our website and/or application.
“We” means ESPRO NOODOE Company Limited.
“Website and/or Application” means the websites and/or applications provided by ESPRO NOODOE Company Limited. For Applications, this Privacy Policy shall apply to any change, improvement, update, addition made to the Applications by ESPRO NOODOE Company Limited, unless the changed, improved, updated or added applications are governed by separate terms and conditions from this Privacy Policy.
“Personal Data” means any information that can directly or indirectly identify a person under the personal data protection law.
“Sensitive Personal Data” means Personal Data relating to racial or ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, labor union information, genetic data, biometric data or any other data as may be announced by the Personal Data Protection Committee.
2. General information
This Privacy Policy is intended to clarify the details and methods of handling Personal Data of users. We may update or amend the Privacy Policy set out below, including as specifically set forth in any part of this Website and/or Application, if any, whether in part or in whole from time to time to ensure compliance with our service guidelines and legal rules that are subject to changes. Therefore, you are encouraged to revisit this Privacy Policy regularly. However, we will post the updated Privacy Policy on our this website or Application. In case where the change is material, we will notify you. In addition, where it is required by lay, we may further request your consent.
This Privacy Policy is intended to apply to Personal Data related to the registration for the service, subscription, use of goods and services provided by us, any company in our group, or our business partners, access to and use of content, features, technology or any functions displayed on this Website and our Applications both existing and those that we will develop or make available in the future.
3. Personal Data collected, used, disclosed and data collection methods
We collect information by using various technologies such as cookies, which are small files stored on your device that enable the website to remember each visit to the website or the way you use it (more information about cookies). The data we collect about you may be Personal Data that we directly collect from you or indirectly collect from any other source. These include:
Data you provide directly: We collect information that you provide to us, such as the information you enter or contained in documents you submitted when registering for the service, such as, information contained in national ID card, passport, power of attorney, birth certificate, house registration, adoption registration documents, court order as to parental responsibility, other documents indicating a parental responsibility over a minor user or the authority of a person to act on behalf of a user, information used to subscribe to ESPRO services and participation in the Website or Application activities, survey data, user account information, information that you have updated in your user account, information obtained from your contact with us or our team, including voice recordings from your communication with us or our team, contact details record, or other information obtained from the user account that we have reasonable grounds for believing that it is under your control, including but not limited to any information on the user profile page and service records such as name, surname, telephone number, national identification number, passport number, facial photo, date of birth, address, gender, and all your comments on the Website or Application (if any) to be stored in your account.
Data obtained from your use of the service and which may be collected from other sources: We collect information about the services you use and how you use them. This includes but is not limited to, information of the device you use for accessing the Website or Application, appointment information, treatment rights eligibility, payment records, and/or computer traffic data (log), contact information records and communications between you and other users, and log data, such as, unique device identifiers, IP address, device code and type, mobile network data, connection information, geographic location information, type of browser, web log data, referring website, records on use of Website, login log, transaction log, customer behavior, Application or Website access statistics, access time, search history, use of functions of the Website or Application and the information we collect through cookies or other similar technologies, as well as data about you that we collect from the Smart Device you use which you have authorized to connect with our Website and/or Application, which you have authorized the transmission of that data to our Website and/or Application in order for us to provide services to you.
The foregoing details are examples of information we may collect. We will collect your Personal Data only as necessary and will retain it for the period no longer than it is necessary for the purposes for which it was used as specified in clause 4, or for any longer period as required or permitted by law.
If you refuse to provide any Personal Data necessary for our provision of services or products that you request, we may not be able to offer or provide our products and services to you. This may affect the ability to enter into a contract with you or the performance of our contractual obligations that we have with you. This may also cause you any inconvenience in your access to our product or use of our service in whole or in part and may affect compliance with any applicable laws that we are subject to.
If you provide us with Personal Data (such as your name, surname, address, telephone number, national ID card number) of anyone other than yourself, such as your family member, or dependent, you are responsible for notifying that third party of this Privacy Policy and obtaining their consent (if consent is required) or relying on other legal bases. Furthermore, you have to take necessary steps to enable us to collect, use, and/or disclose their Personal Data in accordance with relevant laws and this Privacy Policy.
We collect Personal Data of minors, quasi-incompetent persons, and incompetent persons, only with the consent of their parents, curator or guardian (as the case may be), or only if permitted by law. If the consent is required, we have no intention to collect Personal Data from persons under the age of 20, without parental consent or as permitted by law, or from quasi-incompetent or incompetent persons, without the consent of the curator or guardian or as permitted by law (as the case may be). Under certain circumstances as prescribed by law, we cannot collect, use, and/or disclose Personal Data of minors, quasi-incompetent persons, and incompetent persons, without the consent of parents, curator or guardian. Therefore, if you are under 20 years of age, or a quasi-incompetent or incompetent person, you must ensure that you have obtained the consent of your parent, curator or guardian (where the consent is required). If we learn that we unintentionally collected Personal Data from persons under the age of 20, without parental consent or as permitted by law, or from quasi-incompetent or incompetent persons, without the consent of the curator or guardian or as permitted by law (as the case may be), we will delete that Personal Data immediately, or will collect and/or disclose that Personal Data, only if we are able to rely on a legal basis other than the consent, or only if permitted by law.
4. Use of Personal Data
4.1 Purposes for collection, use and disclosure of Personal Data
We collect, use and disclose your Personal Data for the following purposes:
1. To ensure that the use of service is in orderly manner and in accordance with the relevant laws, rules, and regulations, and to ensure the performance of duties under the laws and the rules applicable to us now in force and as amended hereafter.
2. To proof or authenticate your identity when accessing services, such as subscription of services.
3. To check the information about your use of the service, for the purpose of developing security standards in using the service, management and protection of IT infrastructure. In this regard, we may use your Personal Data to the extent necessary and may proceed with encryption prior to use and/or to arrange a random check, or run test on a third-party login for risk management, detection, prevention or elimination of fraud, or other activities that are likely to violate the relevant laws, relevant rules of services, or our terms and conditions for use of the Website (“Terms and Conditions of Use”);
4. To increase the efficiency of services provided to you.
5. To contact you via telephone, text message (SMS), e-mail, mail or through any channel to inquire or notify you, to check and verify information about your account, or to survey or provide any other information related to our services as necessary.
6. For any other purposes related to our business operations, such as, for any study, research, statistics and development of service.
7. To conduct relevant targeted marketing or advertising, including content delivery, public relations, activities and promotions as well as providing appropriate advice in order to provide tailored services to you.
4.2 Legal bases for collection, use, disclosure and/or transfer of Personal Data
We rely on the following legal basis to collect, use and disclose your Personal Data.
If it is necessary for the performance of a contract to which you and us are parties, or in order to take steps at your request before entering into a contract with us.
If it is necessary for the purpose of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights of your Personal Data.
If it is necessary for us to perform our task carried out in the public interest or in the exercise of public authority vested in us.
If it is necessary for our compliance with any legal obligation to which we are subject.
If it is necessary to prevent or suppress a danger to a person’s life, body or health.
If we obtain a consent or explicit consent from you where it is necessary for us to obtain the consent.
If it is necessary for the establishment, compliance or exercise, or defense of legal claims.
Data collection and use
For using charging station and includes to access charging station other our products, We will collect and use the following Personal Data:
1. Personal information: national ID card number, name, surname, gender, title and phone number and a credit card. This personal data is of great importance for us to authenticate, to using within charging station and collect payment transaction data includes to contact for solving problem in case cannot use our service in normally and allow customer service contact to you for convenient We will ensure that appropriate security measures are put in place. Your personal data will be properly encrypted and protected.
2. Address data: We will collect and use address data (such as province, district, subdistrict in which you reside) to analysis of the establishment of the charging station to provide access to the electric charging station to cover the service area
3.Verification data: Tax ID number, we will request data only when you want to issue a tax invoice. There will be no request to collect such information during the use of the service.
4.Location: our application has access to your location, You can use it to find a charging station near you. For the convenience of accessing the service.
5.Devices data: The Application has access to camera for using qr code scan to access service of electric charger at the charging station.
5. Data sharing
We will share your data with the following persons or entities:
1.Our partners: We may share your data with trade partners or car company. Your data will not be shared with any third party for commercial purposes without your permission.
2.Any third party that you instruct us and/or give us your consent to share your data with: We may share your data with a recipient designated by you (as defined below).
6. Requesting access to phones by the Application
The ESPRO Application will request access to features on your phone, such as, camera or your location. The app will send you a notification requesting permission to use features on your phone, which you can allow or deny. Please note that if you choose to reject some features, the rejection may partly affect your use of the Application. You may also change permissions for each feature, depending on your permission. We may use your data for the following purposes:
1.Camera: We access the camera function qr code scan to access the charging station.
2.Location: Our Application requests location access for search and locate the charging station near your location.
7. Disclosure of Personal Data to third parties
For the purpose of providing services on this Website or Application, we may disclose your Personal Data to other users or other related third parties, such as a member of your family, holder of parental responsibility, caretaker or Healthcare Facility, as instructed, as required by law, and/or when we obtained your consent (the “Designated Recipient”). We may also disclose your Personal Data to companies in our group, partners who work with us, or other service providers both domestically and internationally, such as IT service providers, data storage and cloud service providers, verification and authentication service providers, or any other person that we have engaged to perform tasks related to Personal Data in order to use your Personal Data for providing services and enhancing the efficiency of the services provided to you, to improve and develop the services and accessibility of content on the Website or Application, to maintain security of the Websites, Applications and networks hosted by us, or for the benefit of our business operations (“Other Recipient”). In disclosing Personal Data to the Other Recipient, we will ensure that they will keep your Personal Data confidential, and not use it for any purpose other than the scope and purposes we have set out in this Privacy Policy.
However, if you believe that any foregoing person to whom we disclose your Personal Data has used your Personal Data for any purpose other than within the scope we have set out in this Privacy Policy, you are entitled to give us notice to take further action. We recommend that you check whether you have used the website, application, product or service provided by the Other Recipient, as it is possible that the Other Recipient collects certain information about your use of services from the Other Recipient’s website, application, products or services separately from us. In such case we are not responsible for the security or privacy of any of your information collected by their website, application, product, or the services. Therefore, You should exercise due care and carefully read privacy policies of their websites, applications, products and services.
In addition, we may disclose your Personal Data pursuant to the rules as required by law, such as, disclosures to government agencies, regulatory authorities, and disclosures requested by virtue of law, such as a request for information for litigation or legal action, a request from a private entities or other third parties involved in legal proceedings, where it is reasonably necessary to enforce our Terms and Conditions of Use, or when there is organizational restructuring, merger or divestment. In such case, we may transfer all or any of your Personal Data that we have collected to the relevant companies.
8. Cross-border transfer of Personal Data
We may send and/or transfer your Personal Data to another person or external entities located in foreign countries, which may include cases where the storage is located outside of Thailand or the use of cloud services in which the destination country where your Personal Data is sent or transferred may not provide personal data protection standards at the same level as provided in Thailand. We will take reasonable steps and implement appropriate measures to ensure that there is an adequate protection level for Personal Data sent or transferred, and as required by law.
9. Personal Data Security
In order to prevent unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of your Personal Data, we have established and/or opted to use a system to collect, use, and disclose Personal Data, whether in hard copy, electronic files and/or any other form, with appropriate security measures, including organizational measures, technical measures and physical measures, covering the components of the relevant information system, taking into account the security implementation specified by the law on personal data protection in order to properly maintain confidentiality, integrity, and availability of the Personal Data according to the level of risk. This includes controlling access to Personal Data and critical information system components, appropriate handling of user access, determining user’s responsibilities, putting in place appropriate measures for audit logging to detect access, alteration, correction or deletion of Personal Data. We also arrange the enhancement of knowledge and understanding related to Personal Data protection and security for personnel concerned.
However, we cannot guarantee that no defects or errors of any kind will arise as a result of the implementation of the aforesaid policies. We hereby reserve our right to deny any claim for loss or damage arising in any case.
10. Links to third party websites, applications, products and services
Our website and/or Application may contain links to third-party websites, products and services. These third parties may collect certain information about your use of services. We are not responsible for the security or privacy of any of your information collected by such third party websites, applications, products or services. You should exercise due care when using their websites, applications, products and services, and carefully read their privacy policies.
11. Contact us
We appointed ESPRO Customer Support as our Personal Data Protection Coordinator. If you have any questions or queries about the Privacy Policy, please contact ESPRO Customer Service Address: 1023 Pattanakarn Rd. Suanluang, Suanluang, Bangkok 10250, email address at info@espronoodoe.com