TNP Car Import car company recognizes the importance of the protection of Personal Data which is any information relating to an identified or identifiable natural person. The high standards you expect from our products and services are our guideline for handling your data which may include the collection, use, disclosure, and/or transfer outside of Thailand. Our aim is to create and maintain the basis for a trusting business relationship with our customers and prospects. The confidentiality and integrity of your personal data is top priority for us.

This privacy policy ("Privacy Policy") applies to our websites, mobile applications, call center, social networking sites, online communication channels, events and activities, and other locations where we collect your Personal Data. However, please read this Privacy Policy in conjunction with the terms and conditions of particular service that you use, which may set out separately regarding the personal information we collect about you.

We reserve the right to modify this Privacy Policy at time to time, so please review it frequently to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our website or application. We will provide additional notice of significant updates.
1. What 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 TNP Car Group, our affiliates, subsidiaries, other companies, or business partners. The specific type of data collected will depend on the context of your interactions with us, and the services or products you need or want from us and within TNP Car Group.

1) Personal details, such as title, full name, gender, age, blood type, nationality, date of birth, marital status, occupation, job title, position, business type, income, year of work, information on government-issued cards (e.g., national identification number, passport number, tax identification number, driver's license details or similar identifiers), information on name/surname change certificate, birth certificate, marriage/divorce certificate, foreigner related documents, work permit, residence certificate, house registration, and title deed, socio-cultural data, photograph, CCTV records, conversation records, life insurance information, VISA related documents, information on withholding tax certificate, VAT registration certificate, user profile (e.g., configured news, audio provider), and other legal documents;

2) Contact details, such as postal address, delivery details, billing address, telephone number, fax number, map, location data, email address, LINE ID, Facebook account, Instagram ID, and other ID from social networking sites;

3) Vehicle details, such as Vehicle Identification Number (VIN), license plate number, brand, model, year, color, engine number, chassis number, vehicle type, mileage, battery, voltage, door and hatch status, oil level, brake wear, position and movement data (e.g. time, position, speed), traffic information, environmental information, sensor information (e.g., radar, ultrasonic devices, gestures, voice), details of car insurance, credit life insurance, compulsory insurance and gap insurance, residual value, accessories, bluebook, vehicle price, due date of next service visit, vehicle check-up documents, details of ConnectedDrive and its operation, GPS coordinate and vehicle location, vehicle history report, police summon and letter, and other vehicle related information;

4) Technical details, such as Internet Protocol (IP) address and telemetry data;

5) Behaviour details, such as information about your behavior, lifestyle, attitudes and convictions and interaction data;

6) Profile details, such as login name or username, profile details and picture, contact history, compliant history, past orders, purchase history, your interests, preferences, feedback and satisfaction survey responses;

7) Marketing and communication details, such as your preference in receiving marketing from us, our affiliates, subsidiaries, third parties, business partners, and your communication preferences; and/or

8) Other information that TNP Car collected, used or disclosed in connection with our relationship, such as, information of our contract (e.g., contract number, contract type, retention period), application form or survey.If you provide Personal Data of any third party to us, e.g., their name, family name, address details, and telephone number for emergency contact and debt collection, family member income; please provide this Privacy Policy for their acknowledgement and/or obtaining consents where applicable.
We will only collect, use, or disclose sensitive data on the basis of your explicit consent or where permitted by law.We only collect the information of children, quasi-incompetent persons, and incompetent persons where their parent or guardian has given their consent. We do not knowingly collect information from customers under the age of 20 without their parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardian's consent. In the event we learn that we have unintentionally collected personal information from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardians, we will delete it immediately or process only if we can rely on other legal bases apart from consent.
2. Why we collect, use and/or disclose your Personal Data
2.1. The purpose of which you have given your consent:
1) Marketing and Communications: To provide marketing, re-marketing, re-targeting, segmentation, communications, sales, special offers, promotions, notices, news, information about other products and services from TNP Car Group, our affiliates, subsidiaries and/or business partners which we cannot rely on other legal bases;

2) Sensitive Data:We may use your sensitive data for the following purposes:  
  1. Sensitive data as shown in the identification document: for verification and authentication purpose;
  2. health data: for facilitation and providing benefit to you;
  3. disability: for facilitation and providing benefit to you;
  4. biometric data (e.g. fingerprint, facial recognition): for verification and authentication purpose;
  5. criminal records: for internal check and investigation.
2.2. The purposes we may rely on and other legal grounds for processing your Personal Data
We may also rely on (1) contractual basis, for our initiation or fulfilment of a contract with you; (2) legal obligation, for the fulfilment of our legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties; (4) vital interest, for preventing or suppressing a danger to a person’s life, body, or health; and/or (5) public interest, for the performance of a task carried out in the public interest or for the exercising of official authorities.
We may collect, use, and/or disclose your Personal Data for the following purposes:

1) To provide products and services to you: To enter into a contract and manage our contractual relationship with you (including contract activation, implementation, re-agreement, early termination and EOT management); to book a test drive; to provide a car registration and other registration services; 

2) Participating in contests, prize draws and similar promotion: To allow you to participate to promotions, special offers, privilege, lucky draws, and other offers/promotions (e.g. for sending you reminder emails, transferring your Personal Data to fulfilment partners), technical campaign, activities, events and seminars, re-marketing, re-targeting and all related advertising services; to process and administer your account registration, gift registration, and event registration; to examine your entire user history, both online and offline; to process on your VISA application and facilitate you on overseas events/trips or incentive trips;

3) Recommendations and Personalization: To recommend products and services that might be of interest to you, identify your preferences, and personalize your experience;

4) Registration and Authentication: To register, verify, identify, and authenticate you or your identity;

5) To contact and communicate with you: To provide you with marketing communications, sales, special offers, promotions, notices, news, and information about the products and services; to process and update your information;

6) To manage our relationship with you: To communicate with you in relation to the products and services you obtain from us, within TNP Car Group, our affiliates, subsidiaries, and from our business partners; to process and update your information as our member; to facilitate your use of the products and services; to handle customer service-related queries, request, feedback, complains, warranty claims, disputes or indemnity; to deal with technical issues, provide technical assistance, car repairing, warranty and goodwill; to conduct customer relationship management activities (e.g., customer satisfaction index survey);

7) Profiling and data analytics: To measure your engagement with the products and services; to undertake data analytics for products and services development, market research, surveys, assessments, behaviour, statistics and segmentation, consumption trends and patterns; to know you better; to improve business performance and better adapt our content to the identified preferences of our customers; to determine the effectiveness of our promotional campaigns; to identify and resolve of issues with existing products and services, and qualitative information development;

8) To improve business operations, products, and services: To evaluate, develop, manage, improve, research and develop the services, products, system, and business operations for you and all of our customers and within TNP Group's, including but not limited to, our business partners; to measure the performance of our physical products, digital properties, and marketing campaigns; to conduct a lead generation and sales funnel management; to assure products and service quality; to conduct a legal consulting; to create aggregated and anonymized reports; to identify and resolve issues; to provide training courses for sales personnel; to improve the request and sales process;

9) To learn more about you: To learn more about the products and services you receive, and other products and services you may be interested in receiving, including profiling based on the processing of your Personal Data, for example, by looking at the types of products and services that you use from us, how you like to be contacted and so on; to learn from the satisfaction survey and customer credit evaluation;

10) Functioning of our sites, mobile application, and platform: To administer, operate, track, monitor, and manage our sites, application and platform to facilitate and ensure that they function properly, efficiently, and securely; to facilitate your experience on our sites and platform; improve layout, and content of our sites and platform;

11) IT Management: For our own business management purpose including for our IT operations, management of communication system, operation of IT security and IT security audit; internal business management for internal compliance requirements, policies, and procedures;

12) Compliance with regulatory and compliance obligations: To comply with legal obligations, legal proceedings, or government authorities' orders which can include orders from government authorities outside Thailand, and/or cooperate with court, regulators, government authorities, and law enforcement bodies when we reasonably believe we are legally required to do so, and when disclosing your Personal Data is strictly necessary to comply with the said legal obligations, proceedings, or government orders; to provide and handle VAT refund service; to issue tax invoices or full tax forms; to record and monitor communications; to handle with traffic fine letter and road tax; to send any transaction to AMLO; to send information to NCB and issue NCB letter to you; to disclose to tax authorities, financial service regulators, and other regulatory and governmental bodies, and investigating or preventing crime;

13) Protection of our interests: To protect the security and integrity of our business; to exercise our rights or protect our interest where it is necessary and lawfully to do so, for example, to detect, prevent, and respond to 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 detect and prevent misconduct within our premises which includes our use of CCTV; to follow up on incidents; to prevent and report criminal offences; to protect the security and integrity of our business;

14) Fraud detection: To verify your identity, and to conduct legal and other regulatory compliance checks (for example, to comply with anti-money laundering regulations, and prevent fraud). This includes to perform internal audits and records, asset management, fraud database, system, and other business controls;

15) Corporate transaction: in the event of sale, transfer, merger, reorganization, or similar event we may transfer your information to one or more third parties as part of that transaction;

16) Risks: To perform risk management, audit performance, and risk assessments; and/or

17) Life: To prevent or suppress a danger to a person’s life, body, or health.
If you fail to provide your Personal Data when requested, we may not be able to provide our products and services to you. We may request your consent from time to time, if required.
3. To whom we may disclose or transfer your Personal Data
We may disclose or transfer your Personal Data to the following third parties who collects, uses and discloses Personal Data in accordance with the purpose under this Policy. These third parties may be located in Thailand and areas outside Thailand. You can visit their privacy policy to learn more details on how they collect, use and disclose your Personal Data as you are also subject to their privacy policies.
4. International transfers of your Personal Data
We may disclose or transfer your Personal Data to TNP Car, our affiliates, subsidiaries, third parties or servers located overseas, which the Personal Data Protection Committee under the Thai Personal Data Protection Act B.E. 2562 has not ruled that the destination countries have adequate data protection standard. When we transfer your personal data outside Thailand, we will take steps and measures to ensure that your Personal Data is securely transferred and that the receiving parties have in place suitable data protection standards or other derogations as allowed by laws. We will request your consent where consent to cross-border transfer is required by law.
5. How long do we keep your Personal Data
We retain your Personal Data for as long as is reasonably necessary to fulfil purpose for which we obtained it, and to comply with our legal and regulatory obligations. If data is processed for several purposes, the data is deleted automatically or saved in a form that cannot be traced back to you once the last specified purpose has been met. However, we may have to retain your Personal Data for a longer duration, as required by applicable law.
6. Cookies and pixel and how they are used
If you visit our websites, we will gather certain information automatically from you by using cookies regarding visitor browsing history.
A cookie is a small text file which is copied onto your hard disk by a website. Cookies do not cause any damage to your computer and do not contain any viruses. The cookies from our websites do not gather any Personal Data about you. As a rule, cookies are only used on our websites for the length of your session for the purpose of anonymous, statistical assessments and for improving user-friendliness. Cookies may occasionally serve an additional purpose in certain sections of the website. You will be informed of this if you access one of these sections.
We also set up pixel which is an analytics tool which we use to understand you more based on your actions that you take on our website. This will help us to know more about you.
You can disable cookies and pixel settings by visiting their browser settings and configure
privacy settings to restrict any future collection of cookies.
7. Your rights as a data subject
Subject to applicable laws and exceptions thereof, you may have the following rights to:

1) Access: You may have the right to access or request a copy of the Personal Data we are collecting, using and disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you.

2) Rectification: You may have the right to have incomplete, inaccurate, misleading, or not up-to-date Personal Data that we collect, use and disclose about you rectified.

3) Data Portability: 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 processing such data on the basis of your consent or to perform a contract with you.

4) Objection: You may have the right to object to certain collection, use and disclosure of your Personal Data such as objecting to direct marketing.

5) Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances.

6) Withdraw Consent: For the purposes you have consented to our collecting, using and disclosing of your Personal Data, you have the right to withdraw your consent at any time.

7) Deletion: You may have the right to request that we delete or de-identity Personal Data that we collect, use and disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.

8) Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.