SWAP & GO Company Limited (hereinafter referred to as “SWAP & GO” or “we”) attaches great importance to the protection of personal information of the applicants and users including other persons who access the application and/or the SWAP & GO website (collectively, “You”) to provide you with the assurance that we will protect and treat your personal data in accordance with applicable data protection laws. Therefore, we have established this Privacy Policy to inform you of the details of the processing of personal data whether it is collected, used and disclosed (collectively, “processing”) through various channels such as requesting services, using the application and/or the SWAP & GO website and any other services that may occur as well as informing you of your rights in your personal data and ways to contact us as follows:

 

1. What information do we collect? and how to store?

      SWAP & GO will collect your personal information by requesting information directly from you, for example, for you to fill out the required form, such as a service application form or asking for information from you or asking you to send us documents containing your personal data. However, there may be instances where we collect your personal information from other sources, such as your employer or organization. This includes the automatic collection and processing of information, such as information collected through the normal operation of the application or website.

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      The personal data collected by SWAP & GO are as follows:

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1.1 General Personal Data

(1) Identity data such as name, surname, photo, age, date of birth and SWAP & GO application user account

(2) Contact information such as telephone numbers, addresses and e-mails

(3) Contact information with us (Communication Data), such as message recording data, picture or sound when contacting or complaints about using the SWAP & GO services

(4) Financial data such as credit card number information and the name of the cardholder bank account number

(5) Automatically-collected information such as access time, IP address, unique number used to refer to a device connected to the network (mac address), log details of switching service usage, user's battery, log records problems encountered by users and Cookie

(6) Other personal data such as location (Geolocation) Record travel information (GPS) and image recorded from CCTV

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1.2 Sensitive Data

      SWAP & GO does not intend to collect and use the religious and blood group information contained in your copy of your ID card for any specific purpose. In the event that you have provided us with a copy of your identification card as a document of contract or to confirm the identity of the applicant, you are requested to conceal the information about the religion and blood group. If you do not conceal the above information, you are deemed to have given us permission to conceal such information and is considered a document that contains such information. It is valid and enforceable in all respects by law. We will collect and use such information only as part of your identification documents.

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      However, if it is necessary for us to collect, use or disclose your sensitive personal information for any specific purpose and no legal exception to the processing is possible, we will seek your express consent.

 

2. For what purposes do we collect, use and/or disclose your personal information?

      SWAP & GO may process your personal data for various purposes as follows:

 

2.1 For the necessity of the performance of the contract or for processing your request before entering into a contract

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      SWAP & GO may collect, use and/or disclose your personal information to perform various operations necessary to use the battery swap service on the SWAP&GO application, such as verifying the identity of the service applicant, creating a service account, paying for the subscription service for the battery swap package various transactions, recording the details of the user's use of the battery swap service, verification and execution of terms and conditions or contracts for the use of services, etc. If you do not provide the information necessary to perform the contract, you may not be able to use the battery swap service on the SWAP&GO application.

 

      In this regard, SWAP&GO has installed a vehicle travel recorder (GPS) system on every electric motorcycle, which is the property of SWAP&GO for the benefit of tracking our assets and as part of the terms or contract of using the service. Therefore, when you use the SWAP&GO electric motorcycle, it may allow us to know the location and record your journey.

 

2.2 For our legitimate interests such as

• Entering into a contract or taking any other action in connection with a contract if you are a representative of a legal entity.

• Notifications or communications with you

• Service development

• Risk management, internal control oversight and management within the organization

• Investigation and management of complaints

• Establishment of legal claims, compliance or exercise of legal claims or raising the defense of legal claims various litigation, as well as proceedings to enforce legal cases

• Security of our assets including the use of CCTV to record images of people in the service area by providing a service of switching batteries

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2.3 For compliance with relevant laws such as legal compliance, orders of government agencies, independent organizations or officials with legal duties and powers, compliance with summons, court orders, police officers, prosecutors, government agencies and reporting or disclosing information to government agencies or independent organizations

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2.4 For other purposes that require your consent

      If SWAP & GO is processing personal data for any purposes that require your consent, we will notify you and obtain your consent, for example:

• Location tracking (GPS) from using the application service on your mobile phone to find a battery swap station that is closest to your location

• Collection and use of location information (Geolocation) and travel data (GPS) to analyze the usage characteristics of the alternate battery service to be used as information for service development

• Collection and use of your contact information. for public relations, marketing news or various promotional programs, etc.

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      In case we ask for your consent, you are free to give consent to us or not. Such consent is not a condition of use. However, in some cases, if you do not give your consent, you may not be able to use certain applications, for example if you do not consent to location tracking (GPS) on your mobile phone, you will not be able to use the search service for a battery swap facility that is close to your location.

 

3. Who do we disclose your personal information to?

      In carrying out the purposes stated in this Policy, we may disclose your information to third parties as follows:

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3.1 Government agencies, state enterprises, public organizations, independent organizations established by law or other agencies as required by law including officials who exercise powers or perform legal duties such as courts, police, etc.

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3.2 Agents, contractors/subcontractors and/or service providers for any operations to us, auditors, lawyers, consultants, air, land or sea passenger or parcel carriers, system developers, etc.

 

4. Sending or Transferring Personal Information Overseas

      We may store your information on servers or cloud computers of foreign service providers and data may be processed using programs or ready-made applications of foreign service providers.

      In any case, when sending or transferring your information abroad, we will comply with the Personal Data Protection Act B.E. 2562 (2019).

 

5. Cookies and Similar Technologies

      When accessing the SWAP & GO website, cookie information is automatically collected. Cookies are data files that are stored on your computer when visiting a website. Some of these cookies are essential. to make the website work perfectly and optional cookies are intended to facilitate website visitors. SWAP & GO wishes to use optional cookies to help us improve our service to you. SWAP & GO will not use optional cookies until you allow us to enable such cookies. You can find details of the use of cookies in the SWAP & GO Cookie Policy [www.swapandgo.co/cookie-policy].

 

6. Period for Collecting Personal Information

      We will retain your personal data for as long as is necessary for the purposes of collecting, using, or disclosing personal data set forth in this Policy and may continue to keep it for as long as necessary for compliance by law or by legal age for the establishment of legal claims, compliance or exercise of legal claims or raising the defense of legal claims or for other reasons in accordance with our internal policies and requirements.

 

7. Your Rights as a Data Subject

      As the owner of your personal data, you have the rights as set forth by the Personal Data Protection Act B.E. 2562, however, you can request to exercise your rights through the channels we have set out in Article 9, which you will have when the data protection laws apply to us. Your rights are detailed as follows:

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7.1 Right to Withdraw Consent

      Where we ask for your consent, you have the right to withdraw your consent to the processing of personal data that you have given us your consent to, unless your revocation of consent is restricted by law or contract to your benefit. The revocation of consent will not affect the lawful processing of personal data for which you have given consent.

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7.2 Right to Access

      You have the right to request access and obtain a copy of your information, which is our responsibility including asking us to disclose the acquisition of such information without your consent to us.

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7.3 Data Portability Right

      You have the right to request that we transfer your personal data that you have provided to us as required by law.

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7.4 Right to Object

      You have the right to object to the processing of information about you in the event of the collection, use or disclosure of personal data about you as required by law.

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7.5 Erasure Right

      You have the right to request that we delete your personal data as required by law. However, we may store your personal data electronically. Some systems may not be able to delete it. In such event, we will arrange for the destruction or rendering of such information as non-identifiable to you.

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7.6 Right to Restrict Processing

       You have the right to request that we suspend our use of your information as required by law.

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7.7 Rectification Right

      In the event that you believe that the information we hold is inaccurate or you change your personal information, you have the right to request that we correct your personal data so that such personal data is accurate, current, complete and does not cause misunderstandings.

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7.8 Right to Lodge a Complaint

      You have the right to lodge a complaint with a competent official under the Personal Data Protection Act B.E. 2562 (2019) if we violate or fail to comply with the said Act.

 

8. Amendments to this Policy Form

      We may update this privacy policy from time to time and when such changes are made, we will announce to you through www.swapandgo.co and/or notify you via email. If your consent is required, we will also seek your consent.

 

9. How to contact

      If you have any questions or would like more details about our privacy notice or would like to exercise your rights, please contact us through Call Center Tel. 02-537-1759.

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      Alternatively, you can contact by writing to E-mail: swap&go@pttplc.com or by writing a letter to our office Address: Swap&Go Co., Ltd. 555/3 EnCo C building, 5th floor, Vibhavadi Rangsit Rd, Chatuchak, Bangkok 10900.

 

 [Announcement as of 10/11/2022]