Personal Data Protection Policy

Element Group, including but not limited to Element Energy (Thailand) Co., Ltd. (“We”), recognizes the importance of protecting personal data. Personal data refers to any information that can identify a person, directly or indirectly. As a data controller in accordance with the Personal Data Protection Act B.E. 2562, we have created this Personal Data Protection Policy (“Policy”) to inform data subjects about the purpose, principles, and security of personal data management. This policy applies to our website(s), mobile application(s), showrooms, social networking sites, activities, and other channels through which we collect personal data, whether directly or indirectly, including information obtained from affiliated companies, subsidiaries, or business partners.

1. Personal Data

1.1 Definitions:

• Personal Data means any information relating to a person that enables the identification of that person, whether directly or indirectly.
• Sensitive Personal Data means personal information about biometric data (e.g., fingerprint scans, facial recognition, voice recognition, retina scanning), or any other information that impacts the data subject in a similar manner as defined by the personal data protection committee.
• Personal Data Protection Laws refers to the Personal Data Protection Act B.E. 2562 and other applicable laws.

1.2 Collected Personal Data
The personal data we collect includes but is not limited to:

• Personal Information: Name, surname, government-issued identification numbers (e.g., identity card number, passport number, tax identification number, driver’s license), signature, photographs, household registration, family details, account details (e.g., user names, passwords), and other similar information.
• Contact Information: Postal address, delivery address, billing address, phone numbers, email address, and social networking site contact details.
• Financial Information: Bank account details, payment information, financial contracts, statements, loans, credit card information, financial history, and any other relevant financial data.
• Vehicle Information: For customers using charger stations related to vehicles, information such as vehicle identification number (VIN), license plate number, make, model, year, color, and related maintenance and insurance details.
• Identification and Authentication Data: Information required for Know Your Customer (KYC) checks, risk management, and anti-money laundering purposes.
• Transaction Details: Payment transactions, including amount, transaction date and time, refund requests, service purchases, and related billing information.
• Electronics Information: IP address, cookies, browser details, device identifiers, location data, operating system, and browsing history.
• Market Analytics and Marketing Data: Customer feedback surveys, participation in market research, preferences, and communication regarding services and offers.
• Sensitive Personal Data: Information regarding religion, health data (if provided), and biometric data as needed for specific claims or services.

1.3 Sources of Collected Data
We collect personal data directly from individuals or indirectly from sources such as business partners, public sources, or through third parties. The data may be obtained when you interact with our services, complete forms, visit our website or use our mobile apps.

2. Purpose of Collecting Personal Data

The purposes for which we collect personal data include:

2.1 For Our Customers:

• To manage relationships with customers, fulfill service agreements, and comply with legal and regulatory requirements.
• To address customer complaints, handle transactions, provide support, and ensure an overall positive customer experience.
• To ensure the security of customer data, perform risk assessments, and comply with legal obligations related to data protection and service integrity.
• To communicate with customers regarding service updates, maintenance schedules, and other relevant information for our charging stations.
• To enable access to charging facilities, monitor usage, and ensure the smooth operation of the charging stations.
• To facilitate payment transactions, process billing, issue receipts, and manage customer accounts for services rendered.
• To analyze user feedback and interactions in order to improve service offerings and ensure that customer needs are met.
• To detect and prevent fraudulent activities, unauthorized access, and other security risks related to our services.
• To facilitate marketing campaigns, promotional offers, and communicate new features or services related to our charging stations.

2.2 For Our Business Partners and Contractors:

• To manage business operations, process payments, provide logistics services, and improve overall service quality.
• For vendor management, training, and operational audits.
• To communicate with vendors, process orders, and review contracts.

2.3 For Web Users, Visitors, and Others:

• To provide and improve our website and app services.
• To monitor and secure our digital platforms, including preventing crimes and enhancing user experience.

3. Disclosure, Sharing, or Transfer of Personal Data

3.1 Within Element Group and Related Parties:
We may disclose or transfer personal data within Element Group, including subsidiaries, business partners, and authorized third-party providers, solely for the purposes outlined in this Privacy Notice.

3.2 Third-Party Service Providers:
Personal data may be shared with third-party service providers who help us with various tasks such as providing aftersales support, conducting surveys, providing marketing services, and more.

3.3 International Data Transfers:
We may transfer personal data to other countries where we operate or to third-party providers, ensuring that personal data is appropriately protected according to applicable legal standards.

4. Data Security

We implement security measures to control access to personal data and to ensure safe processing and storage. These measures limit unauthorized access and prevent data theft or loss. We also implement a review process to ensure that personal data is handled securely at all stages.

5. Duration of Collection

We retain personal data only for as long as necessary for the purposes specified in this Policy. Our general retention period is up to 10 years, after which data will be anonymized or deleted in accordance with our data retention and disposal policies.

6. Your Rights as a Data Subject

As a data subject, you have the following rights:

6.1 Right to Access Information: Request a copy of the personal data we hold about you.

6.2 Right to Correct Data: Request correction of inaccurate or outdated data.

6.3 Right to Erasure: Request the deletion of your personal data under specific circumstances.

6.4 Right to Data Portability: Request to transfer your personal data to another entity in a structured, commonly used format.

6.5 Right to Object to Processing: Object to the collection or processing of your personal data in cases where we rely on legitimate interests, public tasks, or legal obligations.

6.6 Right to Restrict Processing: Request to suspend the processing of your data.

6.7 Right to Withdraw Consent: Withdraw consent for processing personal data at any time.

6.8 Right to File a Complaint: Submit complaints to the relevant regulatory body regarding violations of your rights under the applicable data protection laws.

7. Providing Personal Data of Third Parties

If you provide personal data of third parties to us, you confirm that you have informed them about this Privacy Notice and obtained their consent, where necessary, for the use of their personal data.

8. Use of Cookies

We use cookies and similar technologies on our website to enhance user experience and manage services. For more details, please refer to our Cookies Policy.

9. Amendments to This Privacy Notice

This Privacy Notice will be reviewed periodically and may be updated to reflect changes in data processing activities or legal requirements. When changes occur, we will notify you through our website and provide the updated version.

10. Contact Information

For any inquiries or requests regarding your personal data, please contact us at:
Element Energy (Thailand) Co., Ltd.

Email: service@elementenergy.io

Phone: 088 635 1661

Address: 17 Soi Rama IX 60 (Soi 8 Seri 7), Phatthanakan Sub-District, Suan Luang District, Bangkok, Thailand 10250

Website: https://elementenergy.io/

We are committed to addressing any concerns or questions you may have regarding your personal data in a timely and transparent manner.