PRIVACY POLICY

Privacy Policy

Inchcape (Thailand) Co., Ltd. and/or Inchcape Services (Thailand) Co., Ltd. (“Inchcape” or “we”, “our” or “us”) realize the importance of protecting your personal data in accordance with the Personal Data Protection Act, B.E. 2562 (as defined below). This Privacy Policy (“Policy”) describes how we collect, use, store, disclose and/or transfer outside the country your personal data obtained from various sources and your rights and practices concerning such data. You have accepted terms and conditions of such use stated in this Policy. If you do not agree and accept the terms and conditions of this Policy, you will not be able to use or access functions and application of all our services and products.

1. Data Controller and Personal Data

“Data Controller” refers to a person or a juristic person having the power and duties to make decisions regarding collection, use or disclosure of person data.

“Personal data” refers to any information you provide us relating to a person, which identifies such person, directly or indirectly, but not including information of a deceased person in particular.

Inchcape is the Data Controller of your personal data collected, used, disclosed and transferred outside the country.

Inchcape is a juristic person organized under the law of Thailand, having the principal office situated at No. 4332, Rama IV Road, Phra Khanong Sub-district, Khlong Toei District, Bangkok Metropolis 10110.

The objectives of Inchcape are to engage in the business of distributing personal vehicles of Jaguar brands in Thailand and providing aftersales services such as vehicle maintenance, granting privileges and other relevant services for the benefits and highest satisfaction of customers and general people by applying information technology as part of our distribution and services.

2. How to contact us

For more information or to exercise your rights stated herein, you may contact us via our website (

https://www.jaguar.co.th) or the contact details below.

2.1 Email us at: marketing@jaguarlandroverthailand.com

2.2 Call us at Tel: Customer Service Center (66) 02-666-7500 hours: Mondays-Fridays at 8.00-17.00 hrs.

3. Collection of your personal data

3.1 Personal data collected by us depends on your relationship with us and services or products you require from us. Your personal data that we may collect, use, disclose and/or transfer outside the country includes, but is not limited to personal data of the following categories:

• Personal profile such as name title, first name, surname, gender, age, career, job title, workplace, position, education, nationality, birthday, marital status, information on any card issued by government organizations (such as Identification Card Number, Passport Number, Taxpayer Identification Number and Driving License details), signature, audio recording, telephone recording, photograph, CCTV footage, house registration and other identity information.
• Contact information such as address, telephone number, facsimile number, location, email address, LINE ID, Facebook account, Instagram ID, and other IDs on social media websites.
• Vehicle information such as serial number, registration plate number, brand, model, year, color, engine number, chassis number, type of vehicle, mileage, battery, voltage, fuel tank level, brake erosion, location and movement (such as time, position and speed), auto insurance, body kits and accessories, Connected Service accessories (such as signal transmitter and SIM card), vehicle registration manual, vehicle inspection documents, information obtained from Connected Service usage, GPS information and vehicle position, vehicle history report and other relevant vehicle information.
• Financial information such as credit card and debit card information, account number and type of account, Prompt Pay information, current assets, revenues and expenses and other financial information.
• Transaction information such as payment information, date and/or time of payment, paid amount, method of payment, refund information, registration, interest, down payment, installment amount and number of installments, date and place of purchase of products or services, address/date and time of vehicle acceptance, service application form, reservation form, acknowledgement form, signature of receiver, receipt, invoice, transaction, history of transactions, transaction status and other information of services or products that you purchased.
• Marketing and communication information such as your option for receiving marketing information from us, our affiliates, partner companies and your communication options.
• Target customer information such as target customer code, vehicle and vehicle color in use at present, test drive information, buying plan, vehicle of your interest, model of your interest, record of follow-up information (such as car service center visits and reservation information), source (such as from car service center visits, recommendation of other persons, motor show, existing customer, social media website), reason of unsuccessful closing of sales and your interest in Inchcape’s activities.
• Profile information such as user account, Application registered name or user name, history of using our services and products, photograph, contact history, complaint history, your interests, needs, feedback and reply in satisfaction surveys.
• Technical information such as IP Address, type and version of browser, your behavior and search format, cookie, Device ID, device model and type and duration and location of access.

3.2 If you provide us with other persons' personal data such as first name, surname, address and telephone number in case of emergency communication or family member who uses your vehicle, you shall ensure that you have the authority to do so and we are legally granted permission to use personal data of other persons under this Policy. Please provide those persons with this Policy for their acknowledgement and/or consent (or applying other legal basis as exemption of consent) to deliver such information to us under this Policy.

3.3 We shall not use sensitive personal data such as race, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data and biometric data, except being permitted by laws or given your express consent.

You shall ensure that all your provided personal data is complete, accurate and true.

4. How to obtain and collect personal data:

We may obtain and collect your personal data by the following methods:

• Your personal data provided to us: you may directly provide us with your personal data which usually occurs when you contact us for more information, fill in online forms or documents, subscribe or register to receive or obtain information on products, services or benefits from us or when you send us your feedback.
• Your personal data automatically collected by us: we may collect certain technical information concerning your device, behavior and search format which is personal data collected by Cookies and other similar technologies. We will inform you prior to usage.
• Personal data obtained from the third party: sometimes we may obtain your personal data from the third party such as affiliates, Inchcape car dealers, our service providers or business partners if those companies are given permission to disclose your personal data to us under the personal data privacy policy and/or in case that you have given your consent to such third party to disclose your personal data, as the case may be.

5. Purposes and legal basis of collection, use and disclosure of personal data

5.1 We collect, use and disclose your personal data for the following purposes (collectively referred to as “Purposes”).

• To provide you with products and services: To manage, enter into any agreements and perform our obligations under any agreements or obligations made by and between you and us or organization represented by you such as test drive booking, vehicle delivery, performance of product sale and purchase agreement, services concerning payment as well as verification, confirmation and cancellation of transaction, product warranty, negotiation on insurance and other services concerning insurance, registration for services concerning vehicles and other services, delivery of welcoming package, aftersales services such as car maintenance and repair bookings to identify your car position, other services provided to you such as navigation system, emergency service, facilitation and problem solving services, making appointments with car service center, checking repair history and vehicle information to consider offering loans and credit scores, to process payment results, issuance of receipts, outstanding amount, invoice and buying evidence, to buy or sell secondhand vehicles or propose bidding to bid for vehicles, to inform you of vehicle recall, granting of benefits and other services provided by us and Inchcape car dealers as the service provider or requested by you.
• Registration and identity verification: To check and verify your identity for any registration and services provided by us.
• To improve business operations, products and services: to evaluate, analyze, manage, improve, conduct research, plan, conduct survey and statistical analysis in order to improve quality and safety of our products and services such as satisfaction in our products, satisfaction concerning sales of products or provision of services of Inchcape car dealers, to evaluate performance of our products, digital media and marketing campaigns, patterns and trends of consumption, behavior etc., as well as information on your preference and interest in our products or services or to create comprehensive and anonymous reports, to perceive problems and solutions or to train our employees and conduct employee performance assessment to improve our business operations, products and services.
• To manage our relationship with you: to communicate with you on products and services that you receive from us, our affiliates, Inchcape car dealers, service providers or business partners, to remind you of relevant information including car registration or insurance renewal, to process and update your data in our member database, to provide information on your vehicle, prepare travel reports and check vehicle status and information, to maintain relationships with our customers, to facilitate you in using our products and services, to provide assistance and coordination, receive opinions or answer questions concerning our products and services.
• Marketing and communication: to notify you of our and/or Inchcape car dealers, service providers, business partners news, information, public relations, communication and sales promotions of products or services, to send you invitation letters to participate in our activities via our and/or Inchcape car dealers, service providers, business partners communication channels such as website, email, telephone, facsimile, mail, SMS, MMS or social media.
• Information technology management (IT): to manage operations concerning information technology, communication system, maintenance and inspection of information technology security and inspection of information technology security, business management for compliance with requirements, policies and internal procedures.
• Legal compliance: to comply with laws, rules, regulations, restrictions, orders, requirements and our legal obligations.
• Risk: to manage risks and perform audit performance and risk assessment.
• Protection of our benefits: To fulfill the security purposes such as photo taking and video recording, to exercise our rights and protect our benefits as necessary and in lawful manner such as to detect, prevent and respond to complaints, to manage and prevent property loss, to detect and prevent offences in our premises or computer system.
• Detection of fraud: to verify your identity to ensure compliance with laws and other regulations (such as to comply with anti-money laundering and anti-corruption laws) as well as internal audit and recording, property management, fraud database, system and control of other businesses.
• Corporate transaction: In case of sale, transfer, merger, rehabilitation or other similar cases, we may send or transfer your data to one or more third parties as part of such operations.
• Life: to prevent or suppress any danger to a person's life, body or health.

5.2 We collect, use, disclose and/or transfer your personal data under any of the following legal requirements or basis:

• It is for compliance with laws to which we are subjected.
• It is necessary for the performance of agreements in which you or any organization represented by you is a contract party or in order to proceed your request prior to execution of such agreements.
• It is necessary for protecting our legitimate interests or other persons.
• It is for preventing or suppressing a danger to a person's life, body or health.
• It is for public interest in performing missions for public interest or exercise of official authority.
• In case that it is necessary to obtain your consent for some activities concerning collection, use or disclosure of your personal data, we will ask for your consent prior for use of your personal data.

5.3 In case that we may use your personal data for purposes other than those mentioned above, we shall send you a written notice which specifies information on such purpose and also asks for your consent prior to use.

5.4 In case that it is necessary for us to collect your personal data for compliance with laws or agreements that require personal data for execution and you cannot provide us with your personal data upon our request, we may not be able to fulfill such relevant purposes mentioned above.

6. Disclosure of personal data

6.1 We may disclose your personal data to the third party which collects, uses or discloses personal data for the purpose of this Policy. You may read the policy of such third party to learn about more information on how such third party collects, uses or discloses your personal data as you are subjected to those privacy policies separately.

6.2 We may disclose your personal data under the purposes stated herein to the following third parties:

• Inchcape’s affiliates: As we are part of Inchcape group of companies which collaborate to provide customer services and system services, we may have necessity to transfer your personal data to those affiliates or allow such affiliates to access your personal data for the purposes mentioned above.
• Inchcape car dealers: we may share and obtain your personal data from Inchcape car dealers and service centers chosen by you or near you to provide you with our services. You can learn more information on https://www.jaguar.co.th
• Our service providers: we may share your personal data with our external service providers or product suppliers for provision of services on behalf of us or provision of products and services for you.
• Our business partners: inside and outside the country such as auto parts and components manufacturers and suppliers, car rental business, insurance business, financial institution business, retail business, telecommunication business and restaurant business that we may jointly offer or offer products or services for you.
• Third party as prescribed by laws: In some cases, we may have to disclose or share your personal data in compliance with laws or regulations, including compliance with law enforcement authorities, courts, competent officials, government organizations or other third parties if we believe that it is necessary to perform our duties in accordance with laws or regulations or to protect our rights, other persons’ rights or to ensure personal safety or to examine, prevent or deal with problems concerning corruption or security or safety.
• Consultant: including lawyers, technical officers and auditors who provide assistance to our business operations and exercise the right of claim in accordance with laws and defend for the right of claim.
• Assignee of rights and/or obligations: In case of business rehabilitation, merger, transfer, in whole or in part, sale, acquisition, joint venture, grant, assignment or disposition of, in whole or in part, business, property or share or other similar transactions.

6.3 We may disclose your personal data to the third party as stipulated or permitted by laws.

7. Transfer and protection of personal data

7.1 As we are part of Inchcape affiliates, we may transfer or transmit your personal data among the affiliates to collect, use and disclose your personal data under the purposed mentioned above in order to enable you to access our services, take care of our customers, make decisions on service improvement, develop content or other purposes specified herein.

7.2 When your personal data is transferred to Inchcape affiliates overseas, we shall comply with laws regarding your personal data and also security measures to ensure of adequate protection for your personal data. We shall also ensure that the transferee outside the country will protect your personal data with the protection standard equivalent to personal data protection under the law of Thailand, if necessary.

7.3 In case that it is necessary for use to transfer your personal data outside the country, if we found that the personal data protection standard of the third party overseas is inadequate under the personal data protection criteria announced by the Personal Data Protection Committee, we will ask for your consent or apply other relevant legal basis which allows us to transfer your personal data outside the country.

8. Retention period

8.1 We shall keep your personal data for a period as deemed necessary to achieve the purposes of this Policy and to perform our obligations under applicable laws. When your personal data is unnecessary or permitted by laws to be kept, we shall delate or destroy such personal data without notifying you.

8.2 Retention period may vary on the purposes of personal data collection. In case that such personal data is intended for short-term use such as for any specific task, marketing activity or the purpose of recruitment, we may delete or destroy such personal data after the end of such period.

8.3 You are entitled to delete, destroy or anonymize your personal data in some cases, unless we have the necessity to keep your personal data as prescribed by laws.

9. Privacy policy for minors

Our products, services and website are not intended or purposed to collect personal data of any minor aged below 20 years old, quasi-incompetent and incompetent. If you are a minor, quasi-incompetent or incompetent who wants to contact us for any transaction, you have to be given consent by your parents as stipulated by laws, legal guardian or curator before contacting us or giving us your personal data.

10. Inchcape car dealers

Inchcape and its dealers are separate juristic persons and each has its own privacy policy. If you have any question concerning the dealers' personal data protection practices and if you do not want to receive any news and information, public relations, communication and sales promotions of products or services from the dealers not related to Inchcape, please directly contact such dealer.

When you buy or hire lease a car from the dealer, the dealer shall disclose your personal data to us. We and the dealer are separate juristic persons and you should read the dealer's privacy policy to ensure that you thoroughly understand the dealer's personal data protection approach and practices. In addition, generally, as the dealer is the first communication channel with you, the dealer will be able to provide you with information on its personal data protection practices. Although Inchcape fully encourages the dealers to ensure that they comply with the personal data protection law and provide them with information on personal data protection obligations, Inchcape shall not be liable for legal compliance of the dealers.

11. Your rights in personal data

You have the following rights concerning your personal data in our possession. If you intend to exercise your right, you may contact us according to details in "How to contact us".

11.1 Right of access

You may request to access or obtain your personal data provided for us, except when refused by the laws or court orders or possibly causing damage against other persons' rights and liberty.

11.2 Right of correction of personal data

You are entitled to correct your personal data if your personal data in our possession is incorrect or incomplete.

11.3 Right of request to delete or destroy personal data

You are entitled to request to delete or destroy or anonymize your personal data to become anonymous data which cannot identify the data subject, unless there are legal exemptions such as when collection of personal data is necessary for the performance of agreement or for the establishment, compliance or exercise of legal claims or defense of legal claims or other purposes stipulated by laws.

11.4 Right of request for restriction of use

You are entitled to request suspension of use of your personal data.

11.5 Right of objection

You are entitled to object collection, use or disclose your personal data.
If you exercise the right to object collection, use or disclose your personal data, you have the right to inform your intention to additionally delete or restrict the use of your personal data.

11.6 Right of transfer

You are entitled to obtain your personal data collected by us and ask us to automatically transfer such data either in a written or electronic form, except such data transfer cannot be proceeded under the restrictions of our methods.

11.7 Right of withdrawal of consent

You are entitled to withdraw your consent to collect, use or disclose your personal data if you have given us your consent, unless there is a restriction of the withdrawal of consent by law, or the contract which gives benefits to the data subject. However, the withdrawal of consent shall not affect the collection, use, or disclosure of personal data that you have already given consent legally.

11.8 Right of complaint

You are entitled to complain about collection, use or disclosure of your personal data in case that we breach or do not comply with the applicable laws.

12. Amendment of the Policy

12.1 We may amend the Policy from time to time in conformity with changes in the use of your personal data and the applicable laws.

12.2 We will use the latest policy as reference of the method of collection, use and disclosure of your personal data.

This Policy comes into effect on 8 June 2020 or from the date stipulated by laws and supersedes all previous privacy policies stipulated by us.

I have thoroughly read and understood this Policy and hereby accept the terms and conditions in all respects.