1. Introduction

Neta Auto (Thailand) Co., Ltd. (hereinafter referred to as “Neta Auto (Thailand)” or “we” or “our”) acknowledges the importance of confidentiality for visitors or users visiting or using this Website or using the Google Form (“you”). We value your privacy and understand the trust you place in us. We hereby publish the following Legal Notice and Policy on privacy (this Notice/Policy) and explain to you how we treat your privacy and how we identify you using your Personal Data.

Therefore, you are advised to read the following Policy carefully before visiting this Website, interacting with an AI assistant and/or contacting us through Facebook, Messenger, Instagram, Twitter, WeChat, Line or any other channels (“Social Media Platforms”).

The purpose of this Policy is to clarify the collection, usage, disclosure or transfer of your Personal Data (as defined below). We will use your Personal Data in connection with this Policy, and collect your Personal Data only to the extent necessary for handling the affairs between you and us.

Clicking the “Agree” button indicates you have read, agreed to and accepted this Policy and the processing of your Personal Data to the extent specified herein.

2. Personal Data

“Personal Data” means any information that can be used to identify you directly or indirectly, such as age, date of birth, passport number, phone number, ID card number, address, email address (“Email”), location, Internet Protocol (“IP”) address, use of data, cookies and information relating to your use of the Services.

“Sensitive Personal Data” means personal data which the Personal Data Protection Act B.E. 2562 (“personal data protection law”) classified as sensitive data, in which the company has collected, used, disclosed when the company has obtained your explicit consent. Sensitive personal data includes data relating to race, ethnicity, political opinions, cult, religion or philosophical beliefs, sexual behavior, criminal records, health data, disability, labor union information, genetic data, biometric data, or any data which may affect the data subject in the same manner, etc.

3. Collection of Personal Data

We will collect the following Personal Data about you includes, but not limited to the following categories :

• ●

  Your full name;

• ●

  Your email (applicable to account registration, your inquiry, test drive booking, catalog download and our newsletter subscription)

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  Your phone number (applicable to account registration, your inquiry, test drive booking, catalog download and our newsletter subscription)

• ●

  Your contact information, such as your name, address, phone number (only applicable to subscription of certain paid services and delivery services);

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  Your IP address and unique user/device identifiers;

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  Browser type and browsing history;

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  Cookies and tags;

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  Information from third parties and other databases.

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  Information contained in the forms and documents furnished by you to us using a computer or in paper form;

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  Information relating to the agreements you have made, the documents you have submitted and the communications and correspondences between you and us;

• ●

  Information relating to comments, complaints or requests for more information submitted by you to us, whether via website, email or social media and your other user generated content that you provide to us);

• ●

  Information about your communications with us through an AI assistant;

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  Information about your interactions with us or other users on a social media platform;

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  Information in relation to provide you with insurance service and financing services;

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  Information sent by you to us for any other reasons.

4. Legal Basis

We will process your Personal Data solely in light of the following legal bases:

• (1)

  Performance of Contract: for the purpose of performing the contract according to your instructions or as agreed between you and us;

• (2)

  Consent: upon your consent to our processing of your Personal Data. (You may revoke your consent to our processing of such information at any time, provided that your revocation of consent shall not affect the lawfulness of the information processing activities that have occurred prior to such revocation);

• (3)

  Legal Obligations or Regulations: for the purpose of performing our duties in accordance with laws or regulations;

• (4)

  Legitimate Interests: for the purpose of balancing the interests and fundamental rights between you and us through legal means;

5. Process of Personal Data

We use your Personal Data for the following purposes only :

• (1)

  When communicating with you by email, postal mail, letter or other means, certain of your Personal Data will appear on the envelope or shipping carton;

• (2)

  Recording your preferences to manage and enhance our services, including but not limited to managing and enhancing our sales, marketing, communications, corporate image, after-sales service, e-commerce and other services (the “Services”), websites and social media platforms;

• (3)

  Notifying you of our updates and changes to the Services;

• (4)

  Providing you with our Services;

• (5)

  Allowing us to contact you with respect to our products and services directly or indirectly through the social media contact information and other Personal Data you have provided;

• (6)

  Collecting statistical data or basic information about you for use inside the Company for such purposes as adjusting this Website, adjusting our AI services and providing more personalized services for customers or individuals;

• (7)

  Evaluating our Services in order to adjust or rectify this Website or the Services or to carry out internal tests;

• (8)

  Answering your questions, acting according to your instructions or allowing us access to certain information;

• (9)

  Maintaining our database and data backups and facilitating your communication with us;

• (10)

  Performing the agreement between you and us, and/or handling your requests according to the agreed procedure, or entering into an agreement;

• (11)

  Maintaining the security of websites and applications;

• (12)

  Communicating with you and providing personalized services for each customer;

• (13)

  Carry out other activities such as marketing campaigns, exchange of data, promotional activities;

• (14)

  Maintaining network operations and data security, including preventing unauthorized access to computer systems or electronic communication systems, and preventing all types of computer programs designed to cause harm to computers and networks;

• (15)

  Studying and analyzing data for use in customer satisfaction and needs surveys;

• (16)

  Any other purposes in relation to the foregoing.

In certain cases, when we receive your explicit consent, the company may process your sensitive personal data e.g., race, religion, blood type, along with sensitive data as defined by the law, if we are required to process such sensitive personal data.

6. Disclosure and Sharing of Personal Data

We undertake not to sell, provide, transfer or disclose your Personal Data to any third party except to the extent specified in this Policy. We may disclose to or share with third parties, or allow third parties to use, your Personal Data to the extent permitted hereby, which third parties include but are not limited to:

• (1)

  Companies within our system or companies that are our shareholders for the purpose of achieving the desired goals;

• (2)

  Group companies, affiliated companies, service providers, employees, representatives or other third parties engaged by us to support our businesses and provide services to you, such as marketing, technical, postal, telecommunications or information technology personnel. To the extent necessary to perform the Services provided to you, the above third parties may use or disclose your Personal Data on our behalf and according to our instructions, but may not use or disclose your Personal Data for any other purposes;

• (3)

  Companies providing services for us, such as marketing services companies, advertising companies, companies responsible for network registration, companies processing payment and transaction information, and companies responsible for network adjustment. We will transfer statistical data and your Personal Data to these third parties, except for information that can be used to identify you personally;

• (4)

  We will transfer your Personal Data to such third parties as persons purchasing the Company or persons to whom the Company is transferred in any reorganization, merger, or sale or transfer of all or part of the Company’s assets. We will do so in a reasonable manner to ensure that persons purchasing the Company or persons to whom the Company is transferred will act in accordance with the conditions set forth herein;

• (5)

  Other third parties permitted by you.

• (6)

  Persons responsible for handling the relevant events or other persons responsible for dealing with transactions or solving problems who may need to use the information we provide in accordance with the requirements set out in our Personal Data Policy;

• (7)

  Our dealer partners, companies belonging to the same system as us or successors to part or all of our businesses. We may provide a list of our customers as a part of the transaction if any of the above persons requests customers’ information in order to provide better services and customer experience or to sell any of Neta Auto (Thailand)’s businesses;

• (8)

  Any persons providing audit, legal, practical or similar services for us. Whenever any such persons provide such services to enable us to achieve our goals, we will require those receiving Personal Data to agree in writing to treat as confidential such information of the customers. Personal Data may be used solely for the purpose of achieving the permitted goals, and shall be returned or destroyed upon completion of the Services;

• (9)

  Regulators, government officials, civil servants, courts or other competent authorities or individuals prescribed by law we deem necessary to protect (1) individuals; (2) public/national security or the safety of citizens, or (3) the security and credibility of Neta Auto (Thailand) and/or this Website.

If you have provided us with your email address but no longer want to receive email notifications from us, you may delete your name from our list of email addresses by clicking “Unsubscribe” in the email received from us.

7. Cross-border Data Transfer

We have no intention of sending or transferring your personal information to foreign countries. However, if we send or transfer your personal information abroad , we will comply with relevant laws and regulations.

8. Sensitive Information

If you share any of the above information, such as transfer information, geographic information, etc., such information will continue to be shared only with your consent for the purposes of processing your applications or completing your transactions. Additionally, we will never ask you to provide any sensitive information via email, such as credit card number, bank account number, etc. Any request for such information is an act of “phishing”, a deceptive attempt to steal Personal Data, and you shall never respond to any such request. It is recommended that you update your email settings to block the sources of such emails.

9. Information Security and Retention Period

We undertake to maintain the security and confidentiality of your Personal Data in the collection and storage thereof. We will use appropriate and reasonable means to protect the security of your Personal Data, to avoid unauthorized access to or use of your Personal Data, to prevent unauthorized computers from accessing or disclosing your Personal Data, and to ensure that any third party that has received your Personal Data abide by standards equivalent to those applicable to us.

We will store your Personal Data. If necessary to achieve the goals stated herein, we will cause our service providers to store your Personal Data for a given period of time in accordance with the regulations of the regulatory authorities and the relevant laws.

However, the Internet is not a secure environment and we cannot guarantee the absolute security of the Personal Data you send to this Website. We will use fair measures to protect the security of, and prevent unauthorized access to, your Personal Data.

Nevertheless, if you send us any information, including your Personal Data or email address, you do so at your own risk.

Due to the nature of the Internet, we cannot guarantee, and do not guarantee the security of your Personal Data or other information that you may disclose online under any circumstances. You agree to the inherent implications of security with respect to information disclosed via the Internet, and agree that Neta Auto (Thailand) shall accept no responsibility for any security breach, except as a result of any negligence or willful breach of obligations under applicable laws on the part of Neta Auto (Thailand).

10. Cookie

A cookie is a piece of user information stored, including user data. No matter how cookies are used, they may not be associated with Personal Data unless such data has been provided by a user (as further clarified below). If you decline or delete cookies, you will still be able to use this Website, but only parts of this Website; for example, you will not be able to receive special offer alerts or to participate in the contests held. Cookies also help us track and collect data on the clickstream behavior of our users, which allows us to better create contents that interest you and enhance your experience with this Website.

Neta Auto (Thailand) stores and maintains standard logs to record data on all visitors to this Website by using Google Tag Manager or any other analytics program..

These logs contain the following information :

• The Internet domain name, the type of web browser and the operating system used when visiting this Website.
• Your IP address (when you use your computer, your computer will be automatically assigned an IP address). Your IP address may be static or dynamic; a static IP address can be used to trace your identity, while a dynamic one cannot.
• The date and time when you visited this Website.
• The web pages you have visited on this Website.
• The website addresses you have moved to by clicking links.

Neta Auto (Thailand) uses weblog data and clickstreams to design this Website, to identify the most popular features inside this Website, and to make this Website more useful for those who browse it. Weblogs will archive records in sequence, and generally we will not identify individuals using these logs. Nevertheless, we may use logs to identify those who attempt to disrupt, hack into, or cause damage to this Website. We may share data with law enforcement officials if we believe that there is evidence or possibility of a violation of any law or federal (provincial), government or local regulation.

Advertisements about Neta Auto (Thailand) displayed on other websites may be served by the advertising service providers of Neta Auto (Thailand), and we may collect data about your visits to such websites through cookies. Generally, we will not associate such data with you personally except in the above cases. We store such data to use them to improve our advertisements, narrow down our target audiences more precisely, and cater to our customers’ needs and preferences. If you intend to unsubscribe from our advertisements on third-party websites, please go to our service providers’ websites to do so. If you truly do not want to send data to Neta Auto (Thailand), you may choose to opt out on this Website.

By visiting this Website, you agree to our use of your cookies. Generally, web browsers automatically accept cookies by default. Nevertheless, you have the right to change the default settings and disable the use of cookies at any time. You may control the acceptance or rejection of cookies by changing the settings on your web browser (please check with your web browser service provider to find out the way to disable the use of cookies).

11. Third-Party Links

This Website includes links to third-party websites. Please be aware that Neta Auto (Thailand) is not responsible for the protection of your privacy on such other websites. We advise users to keep this in mind even after leaving this Website and to read the privacy notices of websites that collect their Personal Data. This Privacy Notice applies only to the information collected by this Website.

12. Your Rights

We undertake that with respect to our collection of your Personal Data, you have the rights :

• (1)

  To withdraw all or part of your consent;

• (2)

  To request access to and obtain copies of your Personal Data for which we are responsible, or request disclosure of your Personal Data obtained without your consent;

• (3)

  To object to the collection, use or disclosure of your Personal Data if your Personal Data has been collected or used directly for marketing without your consent, unless we have the right to collect, use or disclose such Information without your consent.

• (4)

  To request that we delete or otherwise dispose of your Personal Data, so that it cannot be used to identify you in the event that:

  • a.

    It is no longer necessary to use your Personal Data for the purposes it is collected, used or disclosed;

  • b.

    You withdraw your consent to our collection, storage, use or disclosure of your Personal Data, and there is no legal basis for us to store, collect, use or disclose your Personal Data; or

  • c.

    You object to the collection, storage, use or disclosure of your Personal Data.

• (5)

  To request that we cease to use your Personal Data if it is no longer necessary to collect your Personal Data; and

• (6)

  To request that we keep your Personal Data accurate, complete and free of ambiguity. You may exercise the above rights and the legal rights under the Personal Data Protection Act of 2019 of requests and/or inquiries to us by calling our Call Center at (+66) 02-0239968.

In any of the above cases, we may request that you send copies of your identity documents to verify your identity, so that we can perform our security duties and prevent unauthorized disclosure of information.

We will process your above request promptly within 30 days of receipt thereof. If we are unable to fulfill your request, we will inform you of the reason therefor in a prompt manner.

13. Adjustment and Modification to this Policy

This Privacy Policy may be adjusted and modified from time to time. If there is any modification hereto without your explicit consent, we will preserve your rights under this Personal Data Policy. In the event of any adjustment or modification hereto, we will expressly notify you of the same to seek your separate consent (including but not limited to by sending a text message to your mobile phone, or sending a webpage or email reminder), and the revised Privacy Policy will take effect on the day it is published. If you accept the revised Notice, you will be deemed to have agreed to such modification or adjustment to this Privacy Policy, and the revised Privacy Policy will become the latest version of this Privacy Policy and apply to all of your Personal Data.

Unless otherwise specified, we will keep the previous versions of this Privacy Policy and display them at the end of the latest version of this Privacy Policy for your reference.

14. Disclaimer

The information, images, colors and details contained on the pages of this Website are intended to serve as general reference in relation to the products and equipment we sell. Notwithstanding that we have used every effort to keep the above information accurate and up-to-date, we do not guarantee the reliability, completeness, accuracy or correctness of all of the foregoing information.

The images of overseas prototype vehicles may be displayed in certain cases and can be used as reference only. Therefore, Neta Auto (Thailand) accepts no responsibility for losses resulting from access to or use of this Website and its contents in any country.

All illustrations, photos and details on this Website are those of the latest products. Some auto parts cannot be shown in some photos, and some vehicles displayed may contain accessories. You need to check the vehicles as physical object to ensure accuracy and completeness.

With respect to any links (other than links included in this Website) and any freely available information provided by search engines, Neta Auto (Thailand) shall give no guarantee or warranty as to the accuracy of the information or comments contained therein.

Neta Auto (Thailand) accepts no responsibility for any pornographic content, inappropriate content, restricted-access confidential content, content subject to any form of regulation, or content uploaded by registered users or third parties to websites, microsite pages, sponsor pages and other media platforms.

No such content is transmitted with the permission of Neta Auto (Thailand), and Neta Auto (Thailand) will use its best efforts to immediately remove from this Website the above information for which Neta Auto (Thailand) disclaims all responsibility. Neta Auto (Thailand) accepts no responsibility for the manufacturing/performance or non-manufacturing/non-performance of Neta Auto (Thailand) products or services, including but not limited to losses resulting from the nature of www.neta.co.th, from abnormalities, breaches of warranties or dangers occurring during use of this Website, or from Neta Auto (Thailand) products or services.

15. Recruitment Disclaimer

Neta Auto (Thailand) has established a formal and fair process of screening highly professional employees, and we do not charge any fees or guarantee fees from job applicants in any employment screening process. We will use an email address containing the Company’s domain name (e.g. netaglobal@hozonauto.com) to send job-related emails.

If any person contacts an individual or company in our name to offer fraudulent job opportunities and commit fraud by sending fake emails or making fraudulent calls to induce job applicants to pay fees and/or transfer funds to a bank account, Neta Auto (Thailand) shall accept no responsibility for any losses caused to any individual as a result. Anyone shall avoid falling victim to a scam using any opportunity to work with the Company as an excuse. If any individual receives a phone call or other correspondence offering a job and requesting an interview in our name aiming to get money or gain other benefits, we recommend not giving any reply.

16. Contact Us

If you have any queries or doubts about the collection or storage of your Personal Data, or wish to withdraw your consent, or exercise any right with respect to your Personal Data, please contact our Call Center by calling (+66) 02-0239968.