Privacy Policy

庄和闲 (hereinafter 庄和闲 or “we”, “our”, or “us”) may collect, store, process and use your personal data for providing, maintaining and improving our service as well as upgrading the service quality and optimizing service functions. This Privacy Policy provides information on the personal data processing activities by us. Our Privacy Policy covers http://www.trottop.com/en-th.

We highly value and respect our customer’s privacy. This Privacy Policy aims to better explain how we use your personal data and your legitimate rights. It is recommended to read it thoroughly before you accept our service.

I.  Personal Data We Collect and Why

II.  How We Share Your Personal Data

III.  Rights in relation to Personal Data

IV.  How to Make Requests

V.  Retention Period

VI.  Purpose Limitation

VII.  Cookies and Other Tracking Technologies

VIII. Security

IX.  International Transfer

X.  Changes To This Privacy Policy

XI.  Contact Us

This Privacy Policy does not apply to our authorized retailers, or third parties to whom you directly provide your information including but not limited to, subscription services, insurance companies, or other third parties. These entities are independent of us and responsible for their own collection of information. Please refer directly to those entities and their privacy policies for more information.

I.- Personal Data We Collect and Why

“Personal data” refers to any data or information from which an individual may be directly or indirectly identified (“Personal Data”). When we provide our website, products or services, we have a need to process Personal Data. When you:

 

Access and Use our Website: We collect your following Personal Data to provide our website to you:

(a) your Internet Protocol (IP) address,

(b) your location information (such as may be determined from your Internet Protocol (IP) address),

(c) your internet activity information (such as usage information),

(d) your basic information(such as name, telephone number, E-mail address) you enter when you use our service in our Website,

(e) other information (such as the content of your inquiry) when you use our service in our Website.

We may rely on various legal grounds to collect, use, and otherwise process your Personal Data, including: your consent; that the Personal Data is necessary for providing our website to you; to comply with a legal obligation; to protect your, or someone else’s vital interests; or for a legitimate interest that is balanced against your rights and interests.

 

II.- How We Share Your Personal Data

Personal Data is being accessed or transferred by 庄和闲 and other third parties such as 庄和闲's affiliates, creditors, embassies, governments, 庄和闲 distributors, service providers and collection agencies.

We do not sell your personal data to anyone for any purpose, period. We may also use or share your Personal Data in a de-identified or aggregate manner. The table below illustrates who we may share your personal data with:

Categories of Recipients	Description	Reason for Sharing
Affiliates and subsidiaries	Companies that are owned or controlled by 庄和闲, or where we have a substantial ownership interest.	To assist, operate, enhance, and fulfil services on our behalf.
The distributors or dealers of 庄和闲	Service providers that have entered into relevant agreements with 庄和闲, such as distributors or dealers, which include: 1、HARMONY NEW ENERGY AUTO SERVICE (HONG KONG) LIMITED, 2、JC Motor Limited, 3、Futeng Motors Company Limited.	The distributors or dealers will contact you to provide related services, such as booking test rides or test drive service.
Law enforcement and government authorities	Disclosure of information as required by law, or when otherwise appropriate.	To comply with applicable laws.

When third parties are given access to your personal data, we will take the required contractual, technical and organizational measures to ensure that your personal data are only processed to the extent that such processing is necessary.

In all cases, 庄和闲 will expressly state why such information is necessary, so that you may provide the information at your own discretion. 庄和闲 will not disclose Personal Data provided by you to any party, other than 庄和闲 itself, without prior permission from the you.

III.- Rights in Relation to Personal Data

You generally have the right to ask us:

(a) for access to and a copy of your personal data that we hold;

(b) that some of your personal data is provided to you or sent to another data controller in a commonly used, machine readable format;

(c) to update or correct your personal data in order to make it accurate;

(d) to delete your personal data from our records in certain circumstances;

(e) to restrict the processing of your personal data in certain circumstances;

(f) to object to us processing your personal data in certain circumstances(e.g. in case we process your data for direct marketing purposes).

You can request a respond to your rights. Where we receive a request to exercise one of these rights, we will provide information on the action we take on the request without undue delay and in any event within 15 workdays of receipt of the request.( This time may be extended by a further [72 hours] in certain circumstances, for example, where requests are complex or numerous. Where we do not carry out your request, we will tell you without delay and in any event within [72 hours] of receipt of the request, and we will explain our reasons for not taking the action requested.)

For electronic, telephone calls or text communications, if you no longer want to receive promotional-related emails, you may opt out of receiving them by clicking the unsubscribe button in your mails. If you would like to stop receiving promotional-related or automated text messages from us, you can follow the instructions in the text message you received. If you receive a marketing-related call from us and do not want to receive similar calls in the future, please ask to be placed on our “do not call” list. Please note that we may still send you safety messages or product service issues even if you opt out of receiving marketing messages.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

We hope that we can satisfy any queries you may have about the way we process your data. If you have any concerns about how we process your data you can contact us as described below in the section IV “HOW TO MAKE REUQESTS”.

In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular the data protection authority in the jurisdiction of your habitual residence or place of work.

Finally, please note that where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

IV.- How to Make Requests  

If you would like to access, correct, and delete any Personal Data we hold about you, or exercise any other data subject rights available to you under applicable laws or regulations with the purpose of protecting Personal Data (“Applicable Data Protection Law”), you may submit a request via e-mail at [bydthailand@trottop.com].

 

We aim to respond to your request for access, correction, or deletion within the time required by Applicable Data Protection Law. If we need more time to respond to your request, we will let you know of the reason and the extension period in writing.

 

V.- Retention Period

庄和闲 will not use and store Personal Data longer than necessary to fulfil the above mentioned purposes and shall remove the collected Personal Data after the necessary period to achieve the purposes described in this Policy has passed, or to comply with contractual obligations or as permitted or required by the Applicable Laws.

If we have a relationship with you, we hold your personal information for 1 years from the date our relationship ends. We hold your personal information after our relationship ends to establish, bring or defend legal claims.

Where we have obtained your personal information following a request for information, test drive or any other information on any of our products or services, we hold your personal information for 1 year and 6 months from the date we collect that information, unless during that period we form a relationship with you.

VI.-Purpose Limitation

The Personal Data may only be processed to the extent necessary for the described purposes. Personal Data may in principle not be processed for other purposes other than that for which the Personal Data were collected. If there is a necessity or need to process Personal Data for other purposes, it shall be investigated by 庄和闲 whether the purposes of the intended data processing are compatible with the original purposes. 庄和闲 will provide you with information on that other purpose prior to that further processing.

VII.- Cookies and Other Tracking Technologies

Our websites also collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and Internet Protocol (IP) address, the date and time you access our website, the pages you have accessed while visiting our website, and the Internet Protocol (IP) address from which you accessed our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content.

You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you previously accepted cookies and directed us to share your information on one of our sites, you can change your cookie preference by clicking on the cookie settings link in the footer of that site. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. Some browsers have incorporated Do Not Track (“DNT”) preferences. If you set your browser to signal that you do not wish to be tracked online, we will honour your preference by disabling targeting and social media cookies unless you explicitly consent through our cookie banner to enable these categories. For information on how we use cookies across our digital platforms, please see our Cookie Policy.

We have integrated the consent management tool "consent manager" (www.consent manager.net) from consent manager AB (Håltgelvågen 1b, 72348 Västerås, Sweden, mail@consentmanager.net) on our website to obtain consent for data processing and use of cookies or comparable functions. With the help of "consent manager" you have the possibility to give your consent for certain functionalities of our website, e.g. for the purpose of integrating external elements, integrating streaming content, statistical analysis, measurement and personalized advertising. With the help of “consent manager” you can grant or reject your consent for all functions or give your consent for individual purposes or individual functions. The settings you have made can also be changed afterwards. The purpose of integrating “consent manager” is to let the users of our website decide about the above-mentioned things and, as part of the further use of our website, to offer the option of changing settings that have already been made. By using “consent manager”, personal data and information from the end devices used, such as the IP address, are processed by consent manager. In addition, the processed information may also be stored on your device.

Our legitimate interests in processing lie in the storage of user settings and preferences with regard to the use of cookies and other functionalities. "Consent manager" stores your data as long as your user settings are active. After two years after making the user settings, the consent will be asked again. The user settings made are then saved again for this period.

You can object to the processing. You have the right to object to reasons arising from your particular situation. To object, please send an email to mail@consentmanager.net or contact us as provided in Section XI below.

VIII.-Security 

We strive to maintain the highest standards of security and 庄和闲 has put in place robust technical and organizational measures for the protection of your data in accordance with the current, general state of technology, especially to protect the data against loss, falsification or access by unauthorized third persons. However, the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via our Application. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorized access. In the unfortunate event that a personal data security incident occurs, we will report it promptly and take remedial measures in accordance with the requirements of the law and regulatory authorities.

IX.- International Transfer

We are a global company, and we operate internationally. Your Personal Data will be transferred to and stored at our data center located in Singapore. We comply with Applicable Data Protection Law on the transfer of information between countries to help ensure your Personal Data is protected as described in this Privacy Policy, wherever it may be.

We may rely on various legal grounds to collect, use, and otherwise process your information, including but not limited to: your consent; that the information is necessary for providing our website to you; to comply with a legal obligation; to protect your, or someone else’s vital interests; or for a legitimate interest that is balanced against your rights and interests.

X.- Changes to This Privacy Policy

We may update this Privacy Policy according to changes in our business functions and measures concerning the protection of personal information. If we make changes to this Privacy Policy, we will post the updated Privacy Policy and update the “Last Updated” date. We will also notify you through our website. Where changes to this Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you have.  

XI.- Contact Us

If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at:

E-mail: bydthailand@trottop.com

Postal Address: Interchange 21 building 22^nd fl. Room no.2211, 399 Sukhumvit Rd, Khlong Toei Nuea, Watthana, Bangkok 10110