Personal Data Protection Policy

Great Wall Motor Manufacturing (Thailand) Company Limited, along with its affiliates (collectively, “GWM Thailand” or “we”, “us”, “our” or “ours”), are committed to protecting and respecting any Personal Data you share with us. This Privacy Policy explains what type of information we collect from you and process per the relevant purposes, how it is used and processed by us, how we share information with others, how you can manage the information we hold and how you can contact us when you purchase the products and/or use the services of GWM Thailand including GWM APP (collectively, “services”), and what corresponding rights you have in relation to the processing of your 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 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 the compliance with any laws that we or you are obligated to comply with.

This Privacy Policy only applies to individuals whom we interact with and whose Personal Data we handle in the course of our businesses or in connection with the products and services provided by GWM Thailand. Those individuals include, but not limited only to:
(1) natural person(s) who is our customer / service user (either existing or prospective;
(2) in case we contact our corporate customers and business partner, this includes authorized persons, directors, shareholders, employees, personnel, persons who were ultimately given power of attorney to establish business relationship and any other persons in similar capacity, and contact persons (collectively referred to as “Connected Persons”) of our corporate customers or business partners;(3) visitors and users of our websites, social media platform, and any other individuals about whom we obtain Personal Data (e.g., your family member, spouse, dependent, beneficiary, legal representatives, agents, or assigned person)
(together, “you” or “your”).

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

Please read this Privacy Policy carefully to understand why and how we collect, use, and/or disclose your Personal Data.
1. The Information We May Collect, Use, and Disclose
1.1. We may collect and process your Personal Data depending on our relationship and the products or services you need from us. The Personal Data we may collect, use, process, and disclose shall include but not limited to the following:

A) Personal Information
We may collect your Personal Data such as title, name, surname, nickname, gender, date of birth, age, hobbies, alias, occupation, work place, nationality, marital status, information on government-issued cards (such as identification card, passport, driver’s license, etc.), mobile phone number, OTP, signature, sound recording, recording of telephone conversations or chat, message, short message, emoji, photos and CCTV footage.

B) Account and Contact Information
We may collect your Account and Contact information such as GWM ID, account registered name or GWM APP username, profile picture, service or product usage history, photo, telephone number, address, province, district address, e-mail address, social media accounts e.g. LINE, Facebook, Instagram; linked accounts e.g. Google, Apple ID; and/or other ID.
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 Policy.

C) Vehicle Information
We may collect your vehicle information such as vehicle status, locking or unlocking status, horn, indicators, engine, windshield, air cleaner, skylight, rear doors. Seat heating and cooling system, intelligent pre-cooling and remote control operation history, vehicle location, active fence, vehicle identification number (VIN), license plate number, brand, model, sub-model, year, color, engine number, vehicle number, vehicle type, mileage, battery, fuel level, after-sale vehicle maintenance record, information about car insurance, details of information received from using the service for using the system for managing the use of cars and monitoring the status of the car (Telematics system), information received from using the used car appraisal service, GWM Certified Pre-owned service, and Other car related information.

D) 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.

E) 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 GWM Partner, affiliate company or business partner, including your preferred communication channel, name, prospect customer contact information, details of interested vehicle, current vehicle, color of current vehicle, test drive information and source of information.

F) Technical Information

We may collect technical information such as Internet Protocol (IP) addresses, cookie data usage, device ID, device model and device type, period of use and details of services accessed.

1.2 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:

A) Account Registration

Creating an account. When you sign up and create an account on GWM APP or website:https://www.gwm.co.th/, you will be required to enter your mobile phone number, verification code, and users personal digital certificate to set up and manage your GWM ID account so that you can use full range of services and functions offered by GWM.

Updating your account. If you change any of your registration details (e.g. profile photo, nickname, gender, date of birth, occupation and hobbies), you can update your account in the “Me” section of GWM APP or “Account Info” section of website. For linked account, linked email, password, and other information e.g. phone number, address, tax invoice information, can be updated in the “Settings” section of GWM APP or “Account Info” section of website.

Linking with a third-party account. You have the option of linking the GWM APP with your Facebook or Google account or your Apple ID. Your mobile phone number is used to verify your account. To change the link with a third-party account, you can edit your account in the “Me” and “Settings” section of the GWM APP.Please note that you can revoke your permission to access location, camera and gallery in the “Settings” and “Permissions” section of the GWM APP.

The data processing that takes place in this context is for the purpose of granting you access to all functions in the GWM APP and all functions regarding the services provided to you, you can withdraw your authorization of location, camera and gallery for better experience in the “Settings” and “Permissions” section of GWM APP.

B) Vehicle Status Management

This function allows you to know your vehicle status via GWM APP. To enable this function, we may collect the following information about your vehicle:

● Six-door status (Hood and back door)
● Window status
● Light status (low beam, high beam, left turn, right turn)
● Total mileage
● Cruising range (Electricity/Oil)
● Oil volume
● Four tire pressure
● Intelligent pre-cooling
● Four tire temperature
● Pocket of Skills
● Open skylight state
● Air conditioner on/off
● Seat conditioner on/off
● Air cleaner on/off
● Car location
● View vehicle alarm information, vehicle fault information

C) Active Fence
This function allows you to view your vehicle location and phone location, to search parking lots, gas stations, food, banks, shopping, hotels, and attractions around you. When the vehicle enters or leaves the currently active fence, the electric fence function will provide SMS and app message reminders.

D) Purchase Vehicle
Test drive: When booking a test drive via the GWM APP and the GWM Thailand website, you must enter your name, telephone number, province, district of residence and/or information about your location (if you allow us to access the data) or any other Personal Data for a test drive. We will collect and process your information in order for GWM business partners (GWM Partners) to confirm test drive request information and show the distance from GWM Partner to your location.

Reserve a vehicle: When you make a vehicle reservation on GWM APP or GWM Thailand website, you will be required to provide your name, phone number, district and province. 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.

Place an order: When you place an order on GWM APP or GWM Thailand website, you will be required to provide your necessary information for the process or deposit payment including name, address, phone number, district, province, email address (for receiving booking confirmation document) and payment information to complete the order. Our third-party supplier “2C2P (Thailand) Co., Ltd.” will help you process orders, deposits and payments. Please see https://2c2p.com/privacyfor more details.

Financial Consult Plan: In order to provide you financial consult plan, you will need to provide relevant information including your name, mobile phone number, province and district on GWM APP and GWM Thailand website.

Car insurance: When you agree to purchase our products offered with car insurance, we may disclose your Personal Data including 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.

Online Customer Service: We provide you with online customer service on GWM APP and website, for example, new car related enquiries.

When you use the Store search or navigation functions, we will embed the HERE API/SDK in our applications. HERE (named “HERE Global B.V.”) will collect your location information. When you use the map service provided by HERE, GWM APP or website requires your consent on the location, please review https://legal.here.com/en-gb/privacy for more information regarding the privacy policy of HERE.

E) Mall
When you shop with the merchants in GWM APP, you will be required to provide your purchase necessary information including name, address, mobile phone number and payment information. For more information on how these third parties collect and process your personal information, please see the privacy policy of 2C2P (Thailand) Co., ltd. ( https://2c2p.com/privacy ) 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.

F) Community Service

Messaging information: When you send or reply to messages via “News” and “Activity” sections, we may collect your messages, along with message-related information (such as your GWM ID, when the message was sent, and whether the message includes a particular word, phrase, photos, or emoji). When you interact with messages sent via “News” and “Activity” sections, we collect information about those interactions. We refer to all of this as “messaging information.””

Event registration: When you register for an event through the “Activity” section, we will collect the information you submit, including your GWM ID, the session you are registering for, your name, mobile phone number, address and email address.

G) Chat
We use the Easemob SDK service from a third party (Beijing Easemob Technology Co., Ltd., hereinafter referred to as ‘Easemob’) to provide you with the [Chat] function. In order to successfully implement this function, you need to authorize Easemob SDK to provide the corresponding service. After your authorization, Easemob will collect your relevant personal information.

For more details about the types of information collected by Easemob, its use, the rules of personal information protection and the opt-out mechanism, please refer to the Privacy Policy (https://www.easemob.com/protocol/en) on the official website of Easemob ( https://www.easemob.com/)

H) Logs and Event Tracking
In the process of using the products and services, in order to (1) ensure the security of your account, (2) understand the product adaptability, (3) identify the abnormal status of the account, and (4) provide you with in-vehicle services that are more suitable for your needs, we may automatically collect your usage and store it as network log information, including:

a) Equipment information: We will receive and record the information about the equipment you use (including your equipment model, the version of your browser, operating system version and other software, hardware and equipment environment information), and equipment location information (including GPS location of your license) according to your specific operation in the software installation and use.
b) Service log information: When you use our products and services, we will automatically collect your detailed usage of our products and services, and save it as a service log, it includes browsing, clicking, searching, collecting, function execution and event time point.

In order to improve the stability and security of our products and services, and provide a better experience for all users, we will embed the Google Analytics SDK in our applications. Google Analytics will collect your IP address, device brand, device model, device operating system and version, and your country of residence to track your actions on our products and services including your browsing and clicking behavior our applications, analyze errors and anomalies. Please visit the Google Analytics Privacy Policy for more information

Please note that separate device information and log information are information that cannot identify the identity of a specific natural person. If we combine such non-Personal Data with other information to identify a specific natural person identity, or combined with Personal Data, such non-Personal Data will be treated as Personal Data during the period of combined use. We shall anonymize or de-identify such information unless we obtain your authorization or otherwise specified by laws and regulations.

I) Car Setting
This function allows you to view your vehicle information, such as the VIN, update time, Engine No., and model of the vehicle. In order to provide this service, we need to collect the aforementioned information from your vehicle.

J) Remote Service
This function allows you to remotely control your car. In order to provide this service, we need to collect some of your car conditions, including lock/unlock, whistle, flashing lights, whistle flashing lights, window, air cleaner, skylight, back door, seat heat, seat ventilation, intelligent pre-cooling and your remote history.

K) Pocket of Skills
GWM APP informs you through push notification about ‘Pocket of Skills’ feature which is an intelligent scenario that allows the vehicle to execute automatically by setting trigger conditions and performing actions on the application side.
While you are using this feature, we may collect and process the following information about you:
a) When you record audio via the application, we need you to grant us the recording permissions on your mobile system so that you can use the recording functionality. Your recorded audio will be uploaded to the cloud, so that we can synchronize the recording to the drive side, to achieve the purpose of automatic playback on the drive side.
b) When you directly upload the audio files which were recorded in your mobile phone, we need you to grant us access to your mobile phone files so that we can complete the upload process of audio files. The aforementioned information and permission we get from you will only be used to perform this function.

Except for the information included in the functions above, certain necessary information has to be collected from you and/or your vehicle, without which we cannot identify your vehicle and provide connected service for you. The aforementioned information mainly refers to the VIN of your vehicle.

L)Alarm Management
This function allows you to get notice while alarm occurs, and service opens or closes. In order to provide this service, you shall open the switch in your phone so that to receive messages, without which this function does not work.

M)After-sales Maintenance
You can book a service maintenance appointment for your vehicle via the GWM APP, which requires you to provide your name, mobile phone number, location information and your vehicle information to provide you with a better service appointment and a service record check function, which will be obtained once when you submit your service appointment and will be used by us for the duration of your use of the Service. We will keep your information until you delete your account, at which point we will stop using it and delete it. You can also refuse to allow us to access your location information again by turning off location access authorization in the system settings section of your phone.

Service Maintenance reminders. We may keep track of your GWM ID, VIN, phone number, mileage and service records with regular maintenance reminders. We may also use this information to assess the quality of the services we provide, and the services our business partners provide to us or on our behalf.

N)Charging Map
With GWM APP, you can easily search for charge points which also come with a navigation function to get you where you need to be with no stress. In order to provide the service to you, we need to collect your location information, you can turn off the authorization in the system settings anytime. When you make a payment by coupon, we may collect the number of your coupon, GWM ID, mobile phone number, VIN, voucher’s information, order information, etc. You can also make the payment through the service and product provided by our business partner 2C2P (“2C2P (Thailand) Limited”). Please see https://2c2p.com/privacy for more details.

When you pay by credit card and request for e-Tax invoice, we need to collect your name, national identification number (or passport number), address and email address.

O)Sharing your vehicle, or driving a shared vehicle
Multiple accounts can be created on the GWM APP, and more than one account can be connected to a single vehicle. If you are driving a vehicle with more than one account connected to it, the user(s) of each account will have access to:
a) the vehicle’s location; and
b)services which show information about the vehicle’s status (for example, its fuel level)

Similarly, if you are driving a vehicle with the GWM APP connected to it, the user(s) of the app will have access to the information and services outlined above. This user or users will be given the PIN to allow your connection to the vehicle.

1.3 We may receive your Personal Data from the following sources:
1) 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, 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 GWM Thailand;
● 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 Company’s Cookies Policy)
● Information that you provided to us through online channels (e.g., GWM APP or GWM Thailand’s website, etc.)
● Information collected before or during your participation as business partner, partnership, or party to a contract with us.

2) In some cases, we may receive your Personal Data and information from third parties or other sources such as our GWM 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.

1.4 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 setting up Privacy Protection in System Preferences.

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.

If you chose to connect an account on the GWM APP to a vehicle which has already been connected to another account, your phone number/email account and the fact that you have requested this connection will be shared, via the GWM APP, with user(s) who connected to the vehicle before you. This user or users will be given the PIN to allow your connection to the vehicle.
2. Purpose of Collection, Use, Disclosure, and How We May Use Your Information
We will only use your Personal Data for the purposes for which we collected it, which is specified in this Privacy Policy. 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.

We may also use your Personal Data for the following purposes:

1) Registration and identity verification to carry out verification of your identity in order to register and access various services from us.

2) Facilitate or assist you in using our products and services e.g. communicate with you about the products and services you receive from us or from GWM Partner, our affiliated company, our service provider or from our business partner in order to carry out various notifications such as maintenance appointments, after sales service, insurance renewal, information update as well as answering your questions and processing orders or granting you access to specific information.

3) Provide you with various services such as vehicle-related services, product warranty, after sales service, services related to vehicle usage management and vehicle status monitoring (Telematics system), services related to insurance, payments, credit financing, buying or selling used cars (GWM Certified Pre-owned), benefits including providing other services that you request to us or to GWM Partner, as well as providing suitable products and services to you, etc.

4) Perform contractual obligations between you and us and/or handle your request to enter into any contract or obligation such as test driving, buying and selling of vehicles, vehicle delivery, product warranty, after-sales service, etc.

5) Marketing communication activities such as notification, public relations, advertising, marketing campaigns, special privilege, event invitation, and activities to promote our products or services, etc., through various contact channels that you provide to us such as GWM APP, websites, telephone, email, SMS, address or other means of contact. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from us by email, SMS, post and telephone or other means of communication.
In general, we will deliver marketing communications and marketing information to you whether it is marketing of our products and services, products and services of GWM Partner, and of selected business partners, relying on the basis of performance of contracts and/or on the legitimate interest basis under Personal Data Protection Laws. Please be informed that your privacy and interests are of the utmost importance to us. We will select marketing activities that are appropriate or in your interest in order for you to benefit from us, where you have shown interest in any products or services; or you have purchased products or received services from us, GWM Partner, or our business partners.

In some cases, we will ask for your consent before delivering certain types of marketing communications and marketing information which we cannot rely on any other legal basis, such as marketing of products or services of third parties that may exceed beyond your reasonable expectations to receive such marketing communications.

6) Manage technology security audits and protections in order to protect the safety of products, websites and applications. Determine network and data security including preventing unauthorized access to our computers and other electronic communication systems and to protect files related to the installation and updates of malicious software (Malicious Software Distribution).

7) Comply with laws, rules, regulations, orders, requirements, rights or duties and/or legal proceeding under the applicable laws such as identity verification according to the requirements of the Anti-Money Laundering Office including to check your provided data against databases, to carry out the processes and steps of customer identification and other security risk checks, management and analysis (including, “know your customer” (KYC), “customer due diligence” (CDD), anti-money laundering, to carrying out checks using agencies such as credit reference agencies, financial crime prevention agencies, tracing companies or public/private information, to prevent fraud and money laundering.

These checks may also be carried out for business partners and their Connected Persons, service provider, or person(s) that you provide Personal Data on. Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch. Any transfer of your Personal Data will always be done securely.

8) Improve our general business operations, product and services: to carry out surveys, including on your overall satisfaction, to analyze data, including marketing data, to conduct profiling, to process data, to conduct market research and statistical analysis, and to prepare data analysis reports (including use of new technologies), to design and develop products and services including related products and services to meet market conditions and consumer wants, including general operation which is within your reasonable expectation. For example, we may use your service usage data to calculate commissions and service fees to our business partners or we may use your opinions from your use of services to predict future market trends.

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.
3. How We May Share or Disclose Your Information
We will only share or disclose your Personal Data for the purposes for which we collected it, which is listed in this Privacy Policy. Normally, we won’t share or disclose your information with other parties that are not specified in this Privacy Policy, 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.

We may share or disclose your Personal Data and information for the purposes of this Privacy Policy to:

1) GWM affiliated companies. In some cases, it may be necessary for us to transfer your Personal Data to such affiliated companies or allow our affiliated companies to access your personal information for the purposes stated above.

2) GWM Partner(s). We may share and receive your personal information from GWM Partners e.g. GWM Partner Stores, banks, insurance companies or insurance brokers.

3) Our service providers. We may share your personal information with third party service providers or suppliers to provide services on our behalf or to assist in the provision of products and services as well as offering products or services to you such as telecommunication service providers, network provider, technology and software provider, logistics and transportation service providers, emergency service provider, research provider, analyze and survey the market service provider for marketing, advertising media, design creation and communication, storage and cloud service providers, insurance service provider, legal service provider, account provider and our auditors, etc.

4) 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 Policy, 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 Policy 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.
4. Legal Basis for Collecting using, Processing and Disclosing Your Information
The legal bases for using your Personal Data as set out in this Privacy Policy 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.
5. Your Rights and Obligations
We respect your legal rights to your Personal Data. We list below your legal rights and the measures we take to protect these rights:

1) The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

2) The right to request that we rectify your Personal Data if it is inaccurate, incomplete or outdated;

3) The right to request that we erase your Personal Data in certain circumstances. 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;

4) In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit this information to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to us.

5) The right to withdraw your consent to our processing of your Personal Data. However, we may still be entitled to process your Personal Data if we have another legitimate reason (other than consent) for doing so. For example, we may need to retain your Personal Data to comply with a legal obligation; In addition, if you withdraw your consent, this does not affect the lawfulness of the processing of your Personal Data prior to the withdrawal of your 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 GWM Thailand due to your withdrawal of your Personal Data specified herein, GWM Thailand 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.

6) The right to object to, and the right to request that we restrict, our processing of your Personal Data in certain circumstances. 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; and

7) the right to lodge a complaint through our contact channel or with the supervisory authority if you think that any of your rights have been infringed by us.

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 Article 13 ‘How to contact us’, and we will reply within 30 days.

We would not respond to your request if it is:

1) Related to the fulfilment of obligations stipulated by laws and regulations by the data controller;

2) Directly related to national security and national defense security;

3) Directly related to public safety, public health and major public interests;

4) Directly related to criminal investigation, prosecution, trial and execution of judgments;

5) The data controller has sufficient evidence to identify that the subject of Personal Data has subjective malice or abuse of rights;

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.
6. Marketing Messages
We may provide advertising or other marketing materials to you relating to goods and services of GWM through email, text message, websites and applications. To provide better user experience, we may recommend products, services and activities based on information in our database. We will only use your Personal Data on a lawful basis or after we obtain your prior explicit consent that involves a clear affirmative action or indication of no objection in accordance with local data protection laws. You can opt-out of marketing messages we send you at any time by emailing us at compliance@gwm.co.th or clicking on the “unsubscribe” link in the marketing e-mails we send you.
7. How We Safeguard Your Information
Personal Data collected by us would be stored and processed primarily in Thailand and Singapore (cloud). We may also process your information in any other country where GWM 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 Policy is processed according to the provisions of this Policy 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) We will adopt encryption and other security measures to transmit and store your Personal Data of particular types

4) 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.

5) 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

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

7) 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.
8. Retention of Your Personal data
The length of time we will hold your Personal Data will vary and will be determined by the following criteria:

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

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 1) and 2) expires, we will (a) erase and permanently destroy your Personal Data or (b) make your Personal Data become unidentifiable (anonymization or pseudonymization)
9. Transfers 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 that we may transfer your Personal Data to locations outside of your country 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.

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 Policy 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.
10. 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 the GWM APP and website.
11. Cookies Policy and Other Tracking Technologies
Our website uses cookies, beacon and similar technologies 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 Policy. 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, web beacons or similar technologies.

We use the following types of cookies:
(1) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into our secure website.
(2) Analytical/performance cookies. These allow us to recognize and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily which helps us better understand user preferences and determine the impact of our advertisements.

(3) Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(4) Advertising/Targeting. These cookies will be placed on your device to record your visit, the page and the link you have visited and followed. Third-party Cookies may also be used by social sharing tools and in embedded content in our services, as well as, to understand users’ interests with the objective to tailor our website and our advertising campaign to suit your interests. You will see less personalized advertising if you do not allow these cookies.

By continuing to use the website, you accept to the use of cookies as outlined above.
12. Updates to This Privacy Policy
We may amend or change this Privacy Policy from time to time by updating our Privacy Policy page on our website. 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.
13. How to Contact Us
We set up a specific department in charge of personal data protection under the local requirement. If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact us as specified below:

a) E-mail address: compliance@gwm.co.th

b) Postal address: The Ninth Tower Grand Rama 9, Tower B, 31st floor, 33/4 Rama 9 Road, Huaykwang, Huaykwang, Bangkok 10310

We will reply to your comments, suggestions and related questions within 30 days.

This Policy comes into effect on 20 July 2024 and supersedes all of our privacy policies earlier designated.