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Personal Data Privacy Notice

For Customers, Trade Partners and the Persons Having Business Relationship

AIONEX Company Limited (hereinafter referred to as "AIONEX" or "we" or "our") gives highest priority to the protection of the personal data of the Customers, Buyers, Trade Partners and the Persons Having Business Relationship (collectively referred to as "you"), and in order for you to ensure that we will protect and manage your Personal Data (as defined below) in accordance with the laws concerning personal data protection, we then established this Personal Data Privacy Notice for your acknowledgement of details of the processing of personal data, whether it be the collection, use and disclosure (collectively referred to as the "Processing") that may be occurred and including to inform you of the rights on your personal data and our contact channels. This Personal Data Privacy Notice ("Privacy Notice") explains what kind of Personal Data (as defined below) we will collect, and how we will use and provide such Personal Data, and how you can manage your own Personal Data.

When we say, "Personal Data", we mean any information relating to an individual, which enables the identification of such individual, whether directly or indirectly, as defined in the Personal Data Protection Act B.E. 2562 (2019) and relevant data protection laws ("Personal Data Protection Laws") and also as listed below. For Personal Data Protection Laws, we are a "controller" of your Personal Data which means we decide why and how it is processed. It also means we are responsible for the processing, which extends to those of our subcontractors who process your Personal Data based on our instructions. We collect Personal Data from you that is necessary for us to either provide you with products and services you've requested, to comply with statutory or contractual requirements or any other pertinent purposes in the course of our business operation. Unfortunately, if you're unable to provide certain Personal Data which is necessary for us to provide our products and services to you or as required by law or as required by the contract, we may not be able to provide you with those products and services. Additionally, this may affect compliance with any laws that we or you are obligated to comply with.

Our Services include services, products and contents for our group companies (referring to our subsidiaries or affiliates, wherein the definition thereof includes domestic and overseas subsidiaries and affiliates), information providers, advertisers, ad distributors and other partners (together with our group companies, hereinafter collectively referred to as the "Partners") and for customers other than customer him/herself.

Services provided by third parties shall follow their own privacy policies, such services shall be expressly listed in this Privacy Notice.

Please read this Privacy Notice carefully to understand why and how we collect, use, and/or disclose your Personal Data.

  1. Types of Persons That We Collect the Personal Data

Under this Privacy Notice, AIONEX shall collect the Personal Data of the following persons:

1.1 "Customer(s) / Buyer(s)" means the person who will purchase or purchases product and/or obtain service from AIONEX, or other persons who contact and inquire for information of product and/or service of AIONEX, the person receiving information of product and/or service through relevant media and the person receiving advertisement and public relations concerning product and/or service of AIONEX, and shall mean to include an ordinary person who is related to or is an agent of the juristic person which is a customer such as the executive, director, employee, hired staff, agent, representative or any other ordinary person, and the person having his/her Personal Data appeared in relevant documents in relation to the conducting of transaction between AIONEX and such juristic person such as the coordinator, the person issuing purchase order, the person receiving product and the cheque payer, etc. including a person that such juristic person has provided data for AIONEX.

1.2 "Trade Partner(s)" means the person who will sell or sells product and/or provide service for AIONEX, whether it has been registered as the trade partner of AIONEX or not, such as the contractual party, service provider and advisor, etc. and shall mean to include an ordinary person who is related to or is an agent of the juristic person which is a trade partner such as the executive, director, employee, hired staff, agent, representative or any other ordinary person, and the person having his/her Personal Data appeared in relevant documents in relation to the conducting of transaction between AIONEX and such juristic person such as the coordinator, the person delivering the product and the cheque payer, etc. including a person that such juristic person has provided data for AIONEX.

1.3 "Person(s) Having Business Relation" means the person which is not a Customer / Buyer, Trade Partner or the operator in AIONEX's Partner that has relationship in the manner relating to the conduct of business such as the person who performs work in the government authority which regulate the conduct of business or supervise the compliance with laws, the person interested to participate in business project or the business project participant, the person interested to make a joint investment or the co-investor, the agent or broker for the procurement of product or service for AIONEX, and shall mean to include an ordinary person who is related to or is an agent of such juristic person such as the executive, director, employee, agent, representative or any other ordinary person, and the person having his/her personal data appeared in relevant documents in relation to the conducting of transaction between AIONEX and such juristic person.

  1. The Information We May Collect, Use, and Disclose

In general, for the collection of your Personal Data, AIONEX shall collect your Personal Data by directly requesting the data from you depending on our relationship and the products or services you need from us; nonetheless, there may be some circumstances that AIONEX collects your Personal Data from other sources such as the company that you are positioned in, your employee, secretary or coordinator, government authorities or state authorities or other sources of publicly disclosed information such as website and searchable data on the internet, etc.

In this regard, the Personal Data we may collect, use, process, and disclose shall include but not limited to the following:

2.1 General personal data

(1) Personal Information: We may collect your identity data such as title, first name, last name, nickname, gender, date of birth, age, hobbies, alias, occupation, work place, nationality, marital status, information on government-issued cards (such as identification card, passport, driving license, etc.), mobile phone number, OTP, signature, sound recording, recording of telephone conversations or chat, message, short message, emoji, photos and CCTV footage, username, etc.;

(2) Account and Contact Information: We may collect your account and contact information such as AIONEX ID, account registered name or AIONEX APP username, profile picture, service or products/services usage history, photo, telephone number, facsimile number, address, a copy of house registration, province, district address, e-mail address, geolocation, emergency contact person, social media accounts e.g. LINE ID, Facebook, Instagram; linked accounts e.g. Google, Apple ID; and/or other ID, secretary information, etc.;

If you provide us with Personal Data of other people for contact purposes, you must have the authority to do so and ensure that we are legally permitted to use their personal information in accordance with this Privacy Notice.

(3) Vehicle Information: We may collect your vehicle information such as vehicle status, locking or unlocking status, horn, indicators, engine and remote control operation history, vehicle location, vehicle identification number (VIN), license plate number, brand, model, sub-model, year, color, engine number, vehicle number, vehicle type, mileage, battery, battery energy level, after-sale vehicle maintenance record, information about vehicle insurance, details of information received from using the service for using the system for managing the use of vehicles and monitoring the status of the vehicles, information received from using the used vehicle appraisal service, and other vehicle related information;

(4) Transactional and Financial Information: We may collect information relating to transactions between you and us, including your financial information such as payment details, date and/or time of payment, payment amount, payment method, details about refund request, registration, interest, down payment, installments and number of installments, date and place of purchase of the product or service, address/date and time of car delivery and other details of the services you receive or the products you purchase, payment information, credit card details, debit card and bank account number information, voucher information, order information and other financial information;

(5) Marketing, Communications and Prospect Customer: We may collect information relating to marketing, communications and prospect customer information such as your choices in receiving marketing information from us or our Partner, affiliate company or business partner, including your personal preferences and interest, preferred communication channel, name, prospect customer contact information, details of interested vehicle, current vehicle, color of current vehicle, test drive information, source of information, information concerning date, time and place having contact with AIONEX, information of the recording of video and/or voice upon having contact with AIONEX, etc.;

(6) Data regarding companies or authorities that you are working in, such as companies or authorities that you are working in, place of work, position of work, etc.;

(7) Data regarding educational profile, work profile, training, proficiency and relevant achievements, etc.;

(8) Data on the participation of meetings between AIONEX and group companies including data on the participation of trainings, seminars, activities or other projects held by AIONEX as there may be the recording of photo, video or voice during such meetings, trainings, seminars or activities;

(9) Other necessary data for profile inspection for evaluation on the appropriateness or risk assessment before making a decision to enter into relevant transactions including for the legal proceeding or legal execution such as marriage status and data concerning assets, etc.;

(10) Opinions, recommendations and complaints;

(11) Records on the participation of relevant activities or projects with AIONEX;

(12) Screening data pursuant to communicable disease prevention measures;

(13) Driving behavior while using AIONEX's vehicle;

(14) Data concerning the utilization of relevant information systems of AIONEX including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.;

(15) Other personal data for the provision of facilitations as necessary such as the preferred food or beverage, etc.

2.2 We may collect, use, process, disclose your Personal Data and/or transfer to third parties, inside and outside of Thailand, when you use our products and/or services according to the function as follows:

(1) Account Registration: Creating an account. When you sign up and create an account on AIONEX APP or website: https://www.aionex.io, you will be required to enter your first name, last name, email (and email verification), and users personal digital certificate to set up and manage your AIONEX ID account so that you can use full range of services and functions offered by AIONEX.

Processing Transaction from your account. To complete payments for pre-orders, reservations, or remaining balances, you will be required to enter your mobile number, billing address, and payment details.

Updating your account. If you change any of your registration details (e.g. full name, billing address), you can update your account in the "My Profile" section of AIONEX APP or "My Account" section of website. For linked account, your linked registration details as per above can be updated in the same manner in AIONEX APP or the website.

Linking with a third-party account. You have the option of logging into the AIONEX website with your Google account or your LINE ID. Your identity will be verified by the third-party service you used to log in. To change the link with a third-party account, please contact us at our call center. Please note that you can revoke your permission to access location, camera and gallery in the "Settings" and "Permissions" section of the AIONEX APP.

The data processing that takes place in this context is for the purpose of granting you access to all functions in the AIONEX APP and all functions regarding the services provided to you, depending on your device, you can withdraw your authorization of location, camera and gallery in the "Settings" and "Permissions" section of AIONEX APP. Likewise for the website, the data processing is to ensure the proper functioning of the features in the website and you can withdraw your authorization of your Contact Information by reaching out to us via our call center.

(2) Order Status: This function allows you to know your order status via logging in to the website.

(3) Purchase Vehicle:

a. Test drive: When booking a test drive via the AIONEX website, you must enter your name, telephone number, email, or any other Personal Data for a test drive. We will collect and process your information in order for AIONEX to confirm test drive request information.

b. Reserve a vehicle: When you make a vehicle reservation on AIONEX website, you will be required to create an account and process transaction from your account (under 2.2 (1)). Our third-party supplier "2C2P (Thailand) Co., Ltd." will help you process orders, deposits and payments. Please see https://2c2p.com/privacy for more details. We will collect and store your information in order to create booking orders and link them to relevant rights and benefits during the pre-sale period.

c. Place an order: When you place an order on AIONEX website, you will be required to follow the same steps as for reserving a vehicle. Our third-party supplier "2C2P (Thailand) Co., Ltd." will help you process orders, deposits and payments. Please see https://2c2p.com/privacy for more details. We will operate strict security inspection on the authorized partners to obtain relevant information and agree with authorized partners on strict data protection measures, so that they can process Personal Data in accordance with our entrustment purpose, service description, this Privacy Policy and any other relevant confidentiality and security measures.

d. Financial Consult Plan: In order to provide you financial consult plan, you will need to provide relevant information including but not limited to your name, mobile phone number, province and district on AIONEX website.

e. Car insurance: When you agree to purchase our products offered with motorcycle insurance, we may disclose your Personal Data including but not limited to your name, mobile phone number, e-mail address, address, ID card number and date of birth to an insurance broker and insurance company to provide insurance contracts and other insurance related services as we offer you in our marketing and promotional campaigns.

(4) We may receive your Personal Data from the following sources:

a. Information that collected directly from you:

  • Information collected during the request submission, application, entering into the service agreements with us (e.g., registering for a test drive, registering for an account, placing an order / reservation, applying for services, requesting for privilege discounts or promotions, etc.);
  • Information collected from your submitted survey, send-receive emails, or other communication channels between you and AIONEX;
  • Information collected from the use of service, network and other related to the services (e.g., your location data within the vehicle or location data from GPS, etc.);
  • Information collected from the Company's websites through cookies (e.g., Google Analytic following the AIONEX's Cookies Policy)
  • Information that you provided to us through online channels (e.g., AIONEX APP or AIONEX's website, other social media platforms etc.)
  • Information collected before or during your participation as business partner, partnership, or party to a contract with us.

b. In some cases, we may receive your Personal Data and information from third parties or other sources such as our Partners, affiliates, service providers or government sectors where such source has the right to disclose your personal data as permitted by laws. If you have previously consented to the disclosure of information to such third parties, we encourage you to read the privacy policies of such third parties to ensure that you understand the guidelines and practices for the protection of Personal Data of such third parties. However, if you have any questions or do not want to receive information, notifications, sales or services promotion of such third parties. Please contact the said third party directly.

2.3 Sensitive personal data

In general, AIONEX has no intention to collect and use religious and blood type data specified in your identification card for any specific purpose. In the event that you provided AIONEX the copy of your identification card, it is requested that you conceal such data. If you did not conceal such data, it shall be deemed that you authorized AIONEX to conceal those data and it shall be deemed that such document with concealed data be valid and legally enforceable in all respects. In case that AIONEX is unable to conceal those data due to some technical limitation, AIONEX shall collect and use such data as a part of your identification documents only.

In case that it is necessary for AIONEX to collect your sensitive personal data, unless otherwise prescribed by laws, AIONEX shall request for your express consent on case-by-case basis.

In this regard, there might be the Processing of the following sensitive personal data by AIONEX:

(1) Religious data;

(2) Data concerning health and/or disability;

2.4 You recognize and understand that there is no compulsion on you to provide us with your Personal Data and any and all Personal Data provided by you to us is with your own volition, intention, desire, and full consent to provide such Personal Data. However, if it is necessary for us to carry out your request to take any action, we may not be able to do this without your Personal Data or your consent to use such information.

If you wish to object to the provision of your Personal Data to us or refuse to receive advice from us, you can do this by reaching out to our call center.

You also understand that we are under no obligation to verify the source from which the Personal Data about you is provided to us, and they are deemed to be provided by you, unless you demonstrate to us that the information was provided to us without your free consent.

  1. Purposes For the Collection, Use And Disclosure of Personal Data

We will only use your Personal Data for the purposes for which we collected it, which is specified in this Privacy Notice. If we need to use your Personal Data for other purposes, we will explicitly notify you and explain the legal basis which allows us to do so.

3.1 In general, whether you are a Customer, Trade Partner or the Person Having Business Relationship, AIONEX may proceed on the Processing of your data on the following purposes:

Clause

Purposes

Lawful Basis

(1)

For contacting and coordination in relation to the business operation of AIONEX.

Legitimate interest basis

(2)

For the collection and use of your personal data such as name-surname, and picture-video in relation to the operations and activities of AIONEX for dissemination or public relations through relevant channels such as internal email of AIONEX and group companies, AIONEX's website, Facebook, LINE, YouTube or other online media of AIONEX or other media such as television and publication, etc.

Legitimate interest basis

(3)

For using as information on the application for using electronic system or enabling the right to access or use internet or relevant electronic systems.

Legitimate interest basis

(4)

For the business planning, reporting and estimation, risk management, audit supervision including the internal audit of the internal audit office and internal management in the organization, including for the benefit of internal operations within AIONEX in relation to the disbursement of payment of the accounting and finance unit of AIONEX.

Legitimate interest basis

(5)

For using as information in the proceedings in relation to Know Your Customer and/or Due Diligence concerning AIONEX's operation including the due diligence investigation on the status of business or other types of profile inspection for evaluation on the appropriateness or risk assessment before making a decision to enter into relevant transactions together with identity proof and verification or the verification of authority, the granting and obtaining of authority for the execution of any agreement or contract with AIONEX.

Legitimate interest basis

(6)

For the proceedings in relation to the assignment of any right, duty and benefit such as merger and acquisition, separation or business transfer which has duly been conducted in accordance with the laws.

Legitimate interest basis

(7)

For using as database of the stakeholders of AIONEX and/or using as an information for relationship management or relevant coordination in relation to AIONEX including opinion survey for analysis and improvement of AIONEX's operation.

Legitimate interest basis

(8)

For the disclosure of information necessary for the compliance with relevant evaluation criteria participated by AIONEX.

Legitimate interest basis

(9)

For the investigation and inquiry of the complaint in the organization, corruption prevention or any other legal proceeding including the inspection and administration of complaints and allegations in relation to the operation of AIONEX or the related person for transparency and justification of all parties.

Legitimate interest basis

(10)

For accepting the application or consideration on the participation in relevant projects or activities of AIONEX such as field trip activity, technical visit, site visit, receiving donation, seminar, training project or other projects of AIONEX or the projects that AIONEX proceeded in cooperation with the third parties or government authorities, etc. as well as the relevant proceedings in relation to the activity participation such as answering quiz for reward, the delivery of reward, the proceeding for management and administration concerning your heath, hygiene and safety such as the arrangement of health insurance for participating the field trip, etc. including for the evaluation, analysis and improvement of such projects or activities.

Legitimate interest basis

(11)

For maintaining security in building area, premises and gas stations of AIONEX including the exchange of cards for the entry and exit of such area, the recording of videos of the visitors of AIONEX or the buildings, premises and gas stations of AIONEX by closed-circuit television (CCTV).

Legitimate interest and legal obligation basis

(12)

For the establishment of legal claim, the granting or obtaining of authority, the compliance, exercise or defense of legal claim and relevant legal proceedings as well as the proceedings for legal execution.

Legitimate interest and legal obligation basis

(13)

For compliance with laws or compliance with court's summon, letter or order of authorities, independent organizations or officers having duties and powers under the laws such as the compliance with a summon, writ of attachment, order of the court, police officers, public prosecutors and government authorities including the reporting or disclosure of information to the shareholders, government authorities or independent organizations such as Energy Regulatory Commission, Ministry of Energy, Revenue Department, Land Department, State Audit Office, the Office of National Anti-Corruption Commission, etc. for compliance with relevant laws.

Legal obligation basis

(14)

For the compliance with laws concerning public interest in respect of public health such as health protection against dangerous communicable disease or epidemic which may be contagious or spread into the kingdom.

Legal obligation basis

(15)

For the management and administration concerning your heath, hygiene and safety.

Preventing or suppressing danger to a person's life, body or health (Vital Interests)

(16)

When you use our online social media such as Facebook, LINE, YouTube and other online media, AIONEX may collect, use or disclose your personal data pursuant to the following purposes:

1. For the performance measurement and the analysis on market survey and market strategies including for business planning, reporting and estimation;

2. For opinion survey, analysis, research and development of products, services and activities of AIONEX to be more suitable with your requirement and for the development of communication and public relations to be suitable with your requirement;

3. For the risk management, audit supervision including for the internal audit of the internal audit office and internal management and administration in the organization such as for inspection and prevention of corruption, etc.;

4. For contacting in order to request for additional information, complaint inspection, complaint management, performance record keeping and the proceedings in accordance with internal procedures of AIONEX;

5. For selection of activity participants, answering quiz through online channels, announcement of activity result, giving of rewards to participants in accordance with conditions prescribed by AIONEX as well as keeping as database of the profile of activity participants of AIONEX;

6. For the compliance with laws, investigation and inquiry pursuant to legal proceedings and any other rule and regulation and for reporting or disclosure of information to government authorities or any other organization by the virtue of the laws or the court's order including for the establishment, compliance, exercise or defense of legal claim.

Legitimate interest and legal obligation basis

Other than the above purposes, AIONEX may further proceed on the Processing of your personal data for the relevant cases as follows:

3.2 In case that you are a Customer, AIONEX may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause

Purposes

Lawful Basis

(1)

For registration and identity verification to carry out verification of your identity in order to register and access various services from us.

Contractual and legitimate interest basis

(2)

For consideration and approval on the request for purchase of product and/or using of service including the procedures for identity verification, verification of authority, granting and obtaining of authority, risk assessment for entering into relevant transactions and the proceedings in accordance with relevant internal procedures of AIONEX for entering into agreement, the operation under the agreement, product delivery, provision of service including contacting and coordination, collection of expenses and delivery of relevant documents, etc.

Legitimate interest basis

(3)

For using as information and supporting documents for any proceeding with banks, financial institutions, Department of Business Development, Revenue Department, Excise Department, Stock Exchange of Thailand, the Office of Securities and Exchange Commission and other relevant external authorities.

Legitimate interest basis

3.3 In case that you are a Trade Partner, AIONEX may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause

Purposes

Lawful Basis

(1)

For proceedings in accordance with relevant procedures prior to entering into agreement such as:

  • Trade Partner registration;
  • Consideration on qualifications of Trade Partner;
  • Preparation of information before entering into procurement process such as creating median price, specifying names and details of Trade Partners in the internal system of AIONEX, etc.;
  • The purchase or acceptance of bidding forms, attending the clarification, the presentation concerning procurement works (as the case may be), price bargaining and announcement of the winning bidder;
  • Invitation to bid, bidding, verification of authority, the granting or obtaining of authority for submission of bidding documents of the bidders and the consideration on qualifications of AIONEX's bidders in accordance with procurement procedures of AIONEX including the case that the bidders are the service provider, legal advisor, accounting advisor, business advisor and tax advisor, auditor, financial advisor, financial institution, advisor on accounting and finance system development;
  • Preparation of confidentiality agreement.

Contractual and legitimate interest basis

(2)

For the necessity in the conducting of transaction between Trade Partner and AIONEX, such as:

  • Identity verification, verification of authority, the granting or obtaining of authority including for using as supporting documents for conducting relevant transactions;
  • Proceedings in accordance with rules, regulations and relevant internal procedures of AIONEX;
  • Consideration, preparation and execution of commercial agreements;
  • The compliance with hiring agreement, service agreement, other commercial agreements and relevant agreements or cooperation between AIONEX and Trade Partners including the procedures for requesting and consideration of relevant documents which may contain personal data of the director of the company which is a third party or representative of state authorities;
  • The acceptance of work pursuant to agreements between AIONEX and Trade Partners, the administration of commercial supplies and products, the issuance of work certification until completion.

Contractual and legitimate interest basis

(3)

For the compliance with relevant laws concerning the conducting of transactions between Trade Partners and AIONEX such as the laws concerning procurement of state authorities, laws concerning taxation, laws on the inspection of rights and benefits of the land, laws concerning state audit, laws concerning securities and exchange and laws concerning official information.

Legal obligation basis

3.4 In case that you are a Person Having Business Relationship, AIONEX may proceed on the Processing of your personal data for additional relevant purposes as follows:

Clause

Purposes

Lawful Basis

(1)

For business communication such as having business contact, appointment, attendance, conference, meeting and converse in relation to products or services and relevant projects of AIONEX or the projects relating to AIONEX including the recording of details concerning such contact.

Legitimate interest basis

(2)

For qualification check or appropriateness evaluation before making a decision to enter into transaction, risk assessment on the entering into relevant transactions, identity identification and verification, verification of authority, the granting or obtaining of authority for the execution of any agreement or contract with AIONEX, due diligence investigation on the status of business or other types of profile inspection and proceedings in accordance with relevant internal procedures of AIONEX.

Legitimate interest basis

(3)

For consideration, preparation, execution of relevant contracts or agreements including the administration of such contracts or agreements.

Legitimate interest basis

(4)

For consideration on the request for participation in the projects of AIONEX or the projects in collaboration between AIONEX and the third parties or government authorities and the relevant proceedings in relation to such projects.

Legitimate interest basis

In case that the personal data collected by AIONEX for the aforementioned purposes is the data necessary for the performance of agreements or the compliance with relevant applicable laws, if you refuse to provide such necessary personal data, AIONEX may not be able to consider entering into transaction or perform administration in accordance with the agreement with you (as the case may be).

Furthermore, in case that you have provided personal data of other person for us, you shall be responsible to inform those people of this Personal Data Privacy Notice and/or the letter requesting for consent (if necessary).

By reading and being notified of this Policy, you hereby understand and acknowledge that we collect, use and process your Personal Data for the purposes as specified in this Policy and in compliance with the applicable laws and regulations.

  1. Period for retention of personal data

The length of time we will hold your Personal Data will vary and will be determined by the following criteria:

4.1) The purpose for which we are using it: we are required to retain the Personal Data for as long as is necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose

4.2) Legal Obligations: the applicable laws or regulations may set a minimum period for which we must retain your Personal Data.

When the retention period of your Personal Data pursuant to 4.1) and 4.2) expires, we will (a) erase and permanently destroy your Personal Data or (b) make your Personal Data become unidentifiable (anonymization or pseudonymization)

  1. Disclosure of personal data

We will only share or disclose your Personal Data for the purposes for which we collected it, which is listed in this Privacy Notice. Normally, we won’t share or disclose your information with other parties that are not specified in this Privacy Notice, unless we reasonably consider that we need to share or disclose it for being compatible with the original purpose, on a legal basis or obtaining your prior consent.

In order to carry out the proceedings for the purposes set out in this Privacy Notice, AIONEX may disclose your personal data to the third parties as follows:

5.1 Companies in AIONEX Group / AIONEX business partner;

5.2 The government authorities, regulatory authorities, state enterprises, state authorities, public organizations, independent organizations established under the laws or other authorities as prescribed by laws including the officers which exercise powers or perform duties under the laws such as court, polices, Revenue Department, the Office of Securities and Exchange Commission, Anti-Money Laundering Office, Department of Labour Skill Development, Welfare and Labour Protection Department, Energy Business Department, Ministry of Natural Resources and Environment, Ministry of Transport, Ministry of Energy, Office of the Ombudsman, State Audit Office of Thailand, House of Representatives Committee, House of Senate Committee, Department of Legal Execution, Office of the Attorney General, State Audit Office of Thailand, the Office of National Anti-Corruption Commission, National Science and Technology Development Agency, etc.;

5.3 Authorities, organizations, or the person relating to the exercise of right of claim, the commencing of legal proceeding, the objection to the complaint or the allegation, the defending of the case of AIONEX such as the parties of the case and witnesses, etc.;

5.4 Agents, contractors/sub-contractors and/or service providers for any operation provided for AIONEX such as professional advisors, transportation service providers, the service firms for the conducting of marketing activities, travel and accommodation agencies, the organizer companies for the convening of activities, trainings or seminars, activity organizers, media producers and advertising firms, insurers, auditors and legal advisors, etc.;

5.5 Persons Having Business Relationship (in case that it is necessary for the compliance with agreements in case that there is a joint operation of project or business);

5.6 Management system standards certification institutes;

5.7 Training participants;

5.8 Shareholders, debenture holders and the representatives of such persons;

5.9 Banks or financial institutions;

5.10 The transferee who received the assignment of any right, duty and benefit from AIONEX including the person assigned by such transferee to proceed on its behalf such as the case of the restructuring, merger and acquisition, separation or transfer of business, etc.;

5.11 Other third parties such as the disclosure of information in e-Government Procurement (e-GP) System, the announcement of relevant persons who have been selected through social media channels of AIONEX or the public relations of activity photos or news and information on the conducting of activities or projects of AIONEX to the mass media and third parties, etc.;

5.12 Hospital or clinic;

5.13 The assignee of rights under the contract such as in the case where we may have a merger, the transfer of all or part of a business, selling, purchasing, engaging in a joint venture, the assignment, transfer, or divestment of part or all of a business, assets, stocks, or any other similar transactions.

In this regard, by reading and being informed of this Privacy Notice, you hereby understand and acknowledge that we share or disclose your Personal Data to relevant persons/third parties for the purposes as specified in this Privacy Notice and in compliance with applicable laws and regulations. You may read the privacy policies of those third parties to learn more about how they collect, use or disclose your Personal Data and information.

  1. Legal Basis for Collecting using, Processing and Disclosing Your Information

The legal bases for using your Personal Data as set out in this Privacy Notice are as follows:

  1. Contractual basis: Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the User Agreement of our websites, products, applications, which you accept; and/or our contract to provide our Services to you);
  2. Legitimate interest Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our websites, products, applications; operate our business and our Services; ensure safe environments for our staff and visitors;
  3. Legal obligations Comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing services);
  4. Consent Where we have your consent, in accordance with applicable legal requirements, to use your information for a particular purpose;
  5. Vital interest for the prevention or suppression of danger to a person's life, body, or health; or
  6. Public interest for the performance of task carried out in the public interest or for exercising of official authorities or duties.
  1. The Submission or Transfer of Your Personal Data Outside of Thailand

We have a global business and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means we may transfer your Personal Data to locations outside of Thailand in order to carry out the purposes specified above. Where there is such a transfer of your Personal Data, we will ensure that it will be done in compliance with the Personal Data Protection Laws or is under your consent and the destination country has sufficient Personal Data protection standards.

In some circumstance, we may be required to disclose your personal data to foreign countries, which may have standards of personal data protection different than those of Thailand because AIONEX has companies in the group which are located offshore. In addition, there are business operation or the conducting of relevant transactions with companies in foreign countries; therefore, we may be required to disclose your personal data to those companies including government authorities, professional advisors and the related persons having necessity to access to such personal data in the normal course of our business operation. Also, there might be the disclosure of information to foreign countries for supporting the commencement of legal proceedings or arbitrations which may be occurred in the future. Furthermore, AIONEX may store your data on computer server or in the cloud of offshore service providers and there might be the processing of data by using programs or applications of the offshore service providers.

In this regard, for the submission or transfer of your data to foreign countries in whatsoever case, AIONEX shall comply with the Personal Data Protection Laws. However, in cases where that the destination country does not have sufficient Personal Data protection standards, the transfer of such Personal Data must comply with exceptions as prescribed by Personal Data Protection Laws or any applicable laws, regulations, and this Privacy Notice except in the circumstance where your consent has been obtained, provided that you have been informed of the inadequate Personal Data protection standards of the destination country.

  1. Your Rights as The Owner of Personal Data and Obligations

As the owner of personal data, you have the rights as prescribed in the Personal Data Protection Laws. In this respect, you can request to exercise your relevant rights through the channels specified by AIONEX in Clause 13, whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to AIONEX. In this respect, your relevant rights shall have details as follows:

8.1 Right to withdraw consent

In case that AIONEX requests for your consent, you shall have the right to withdraw the consent for the Processing of your personal data that has already given to AIONEX unless such withdrawal of consent is restricted by laws or by the agreement that provides you the benefits.

Such withdrawal of consent shall not affect the Processing of personal data legally conducted according to your prior consent. Please note that if you do this, it may impact our ability to provide certain products and services to you. In this regard, you agree that if we are unable to provide you with certain products and services which are specified in any agreement between you and AIONEX due to your withdrawal of your Personal Data specified herein, AIONEX shall not be considered as the default party in such agreement. You shall not claim for any loss, compensation, and/or damages in relation to such agreement.

8.2 Right to access to personal data

You have the right to request for an access to and the request for the copy of your personal data under control of AIONEX, including to request AIONEX to disclose the acquisition of such data that you have not given consent to AIONEX.

8.3 Right to request for the submission or the transfer of personal data

You have the right to request AIONEX to transfer your personal data that you have given to AIONEX as prescribed by laws. Please note that this right only applies to Personal Data which you have provided to us.

8.4 Right to object the collection, use or disclosure of personal data

You have the right to object the Processing of data relating to you in respect of the collection, use or disclosure of your personal data as prescribed by laws. There may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to continue processing your Personal Data and/or to refuse that request to comply with a legal obligation.

8.5 Right to request for the erasure of personal data

You have the right to request AIONEX to delete your personal data as prescribed by laws. Nevertheless, AIONEX may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, AIONEX shall destroy or cause such data to be unable to identify your identity. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it to comply with a legal obligation.

8.6 Right to request the restriction of the use of personal data

You have the right to request AIONEX to restrict the use of your personal data as prescribed by laws.

8.7 Right to request for the rectification of personal data

If you found that the data controlled by AIONEX is incorrect or you have changed your personal data, you have the right to request AIONEX to correct your personal data so that such personal data be accurate, current, complete and not causing misunderstanding.

8.8 Right to lodge a complaint

You have the right to lodge a complaint with the competent officers under the Personal Data Protection Act B.E 2562 (2019) in case that AIONEX breaches or does not comply with such Act.

Response to Your Request: For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. This is to ensure that your data is protected and kept secure. You can contact us according to the ways listed in Clause 13 “Contact Channels”, and we will reply within 30 days.

We would not respond to your request if it is:

  1. 1) Related to the fulfilment of obligations stipulated by laws and regulations by the data controller;
  2. 2) Directly related to national security and national defense security;
  3. 3) Directly related to public safety, public health and major public interests;
  4. 4) Directly related to criminal investigation, prosecution, trial and execution of judgments;
  5. 5) The data controller has sufficient evidence to identify that the subject of Personal Data has subjective malice or abuse of rights;
  6. 6) Responding to the request of the Personal Data subject may cause serious damage to the legitimate rights and interests of the Personal Data subject or other individuals and organizations.
  1. How We Safeguard Your Information

Personal Data collected by us would be stored and processed primarily in Singapore AWS (cloud). We may also process your information in any other country where AIONEX group companies, affiliates, subsidiaries or service providers operate facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance and to create redundancies in order to protect the data in the event of an outage or other problem

We take steps to ensure that the data we collect under this Privacy Notice is processed according to the provisions of this Privacy Notice and the requirements of applicable law wherever the data is located. We have adopted organizational, physical and technical security measures that are in line with the industry standards to protect the Personal Data you provide, and to prevent any unauthorized access, disclosure, use, modification, damage or loss of data, including the following:

1) We use AES256 and RSA and other algorithms or technical measures to ensure encryption with regard to our services and products, especially your sensitive information, such as your location information, recorded audio, etc. We will regularly examine our practice of information collection, storage, and processing (including physical security measures) to prevent unauthorized system access.

2) We will unauthorize our employees and personnel of third parties to access your Personal Data only on a need-to-know basis in order to help us process your Personal Data and provide the services to you. These employees and external personnel (of third parties unauthorized by us) are subject to strict contractual confidentiality obligations.

3) The security of your Personal Data is extremely important to us. We will continue our efforts to protect your Personal Data and implement safeguard measures to prevent your Personal Data from unauthorized access, usage or disclosure. We have a regular testing process to assess and evaluate the effectiveness of technical and organizational measures for ensuring the security of such processing.

4) We will prudently select business partners and service providers, and ensure that such business partners and service providers are contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation.

5) We will conduct security and privacy protection training courses or testing to enhance employees' awareness of the importance of protecting Personal Data.

6) The Personal Data record created through your registration with our services can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties. Please let us know immediately if you believe your password or record has been compromised.

  1. Minors’ Privacy

Our products and services are designed for adults. We will not knowingly collect any Personal Data about minors (under twenty-year-old). Should a parent or guardian have reasons to believe that a minor has provided us with Personal Data without their prior consent, please contact us to ensure that the Personal Data is removed, and the minor unsubscribes from any of AIONEX website.

  1. Cookies Policy and Other Tracking Technologies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you use the website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or other internet-connected devices e.g. smartphone or tablet. Cookies contain information that is stored on your devices' hard drive. When Cookies information directly or indirectly identifies an individual, whether alone or coupled with other information, we will treat such information as Personal Data under this Privacy Notice. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser.

If you decide not to have your Personal Data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means these advertisements will not be personalized for you using first-party or third-party cookies or web.

By continuing to use the website, you accept to the use of cookies as outlined in our Cookies policy.

  1. Amendment of this Privacy Notice

We may amend and update this Privacy Notice from time to time, and if there is such amendment, we will keep you posted through AIONEX website and/or inform you via email. We encourage you to check our Privacy Policy from time to time on our website, as the version of our Privacy Policy which is displayed on our website takes precedence over all previous versions of our Privacy Policy. We will notify you of any changes to this Privacy Policy and obtain your consent, to the extent applicable and if required.

  1. Contact channels

If you have question or require further details concerning the protection of your personal data, the collection, use and disclosure of your personal data, the exercising of your rights or if you have any complaint, you can contact AIONEX as per the following channels:

AIONEX Company Limited

Contact Place: 199, S-OASIS Building, 17th Floor, Room No. 1701, 1702, 1712, Vibhavadi Rangsit Road, Chom Phon Sub-district, Chatuchak District, Bangkok 10900

Telephone: 02-028-2651

Personal Data Protection Officer

Contact Place: 199, S-OASIS Building, 17th Floor, Room No. 1701, 1702, 1712, Vibhavadi Rangsit Road, Chom Phon Sub-district, Chatuchak District, Bangkok 10900

Telephone: 02-028-2651

Email: Hello@aionex.io

This Policy comes into effect on 1 May 2024 and supersedes all of our privacy policies earlier designated.

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