Update Date:
CHANGAN Auto Sales (Thailand) Co., Ltd., which has its legal headquarters at Rooms 7E1-16 and 8E1-16, 7th and 8th floors, Parq Building, 88 Ratchadaphisek Road, Khlong Toei Sub-district, Khlong Toei District, Bangkok City, Thailand (hereinafter referred to as ‘Avatr’ or ‘we’) is the Data Controller for processing your personal data when you use the Avatr mobile application (hereinafter referred to as ‘our application’), that keeps you connected to your Avatr vehicle.
If you have any inquiries or need to exercise your rights pursuant to Avatr Application Privacy Policy (hereinafter referred to as ‘Policy’), please contact us using the following information:
Company: CHANGAN Auto Sales (Thailand) Co., Ltd.
Address: Rooms 7E1-16 and 8E1-16, 7th and 8th floors, Parq Building, 88 Ratchadaphisek Road, Khlong Toei Sub-district, Khlong Toei District, Bangkok City, Thailand, 10110
Email of the Data Protection Officer ("DPO”): compliance@changan.co.th
We are committed to protecting your personal data and privacy rights. This Policy outlines how we collect, use, disclose, process, and protect the personal data that you authorize us to collect or that we actively collect when you use your mobile application. If our vehicle, products, or services have separate privacy policies, those policies will take precedence.
This Policy will help you understand the following:
We process personal data that identifies you, either directly or indirectly, based on the products or services we offer. This may include the following information:
a) To assist you with account registration, login and management:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
When you register an account. |
Account information: User ID, mobile number, verification code, and login password. |
Based on your consent |
|
When you log in your account. |
Account information: Mobile number, verification code, and login password. |
Based on your consent |
|
When you choose to add an authorized account. |
Account information: Mobile number, verification code, authorized mobile number, account expiration date, vehicle control permissions. |
Based on your consent |
Please note that if your account role is authorized, certain functions of the APP may be restricted in order to ensure the safety of both vehicles and accounts. However, you will still be able to use other functions of the APP that are not related to vehicle management.
b) To assist you with vehicle management:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To assist you in binding your vehicle. |
Account information: User ID Basic vehicle information: Vehicle Identification Number (VIN), vehicle name, and vehicle binding status. |
To perform our contract with you |
|
To assist you in removing the vehicle binding. |
Account Information: User ID and verification code Basic Vehicle Information: Vehicle Identification Number (VIN), vehicle name, and vehicle binding status. |
To perform our contract with you |
|
For the safety of your vehicle. |
Account information: Vehicle control safety code. |
To perform our contract with you |
c) To assist you with remote vehicle control:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To assist you in locating your vehicle, you can remotely control the vehicle lights to flash or activate the horn. |
Basic vehicle information: Vehicle Identification Number (VIN) and vehicle control safety code. Vehicle data related to performance, use, operation, and condition: Headlight status and horn status. |
To perform our contract with you |
|
To provide you with the ability to remotely control various functions of your vehicle, including locking, window operation, trunk access, scheduled charging, air conditioning adjustment, and seat ventilation. |
Basic vehicle information: Vehicle Identification Number (VIN) and vehicle control safety code. Vehicle data related to performance, usage, operation and condition: Door status, window status, trunk door switch status, charging opening setting, air conditioning setting, seat ventilation setting. |
To perform our contract with you |
d) To provide you with Bluetooth key service:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To assist you in connecting your vehicle and phone via Bluetooth, we offer Bluetooth-controlled vehicle service. |
Account Information: User ID. Basic Vehicle Information: Vehicle Identification Number (VIN). Vehicle data related to performance, use, operation and status of the vehicle: Door status, window status, trunk door switch status, headlight status, and horn status. Data related to mobile devices: unique device identification code, Bluetooth MAC address, and operation log information. |
To perform our contract with you |
|
To enhance the convenience of the Bluetooth key function, automatic linking is initiated based on the distance between the phone and your vehicle’s location. |
Mobile phone location information: Phone GPS information. |
Based on your consent |
e) To assist you with vehicle charging review and management:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To assist you in viewing power consumption information, charging information and schedule charging. |
Vehicle data related to vehicle performance, usage, operation, and condition: Total electric mileage, remaining range, remaining battery capacity, battery status, and charging status. |
To perform our contract with you |
f) To assist you in checking the vehicle’s status:
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To assist you in checking the status of the vehicle or receive alerts for abnormal vehicle conditions, such as speed, battery status, charging status, interior temperature, air quality, and status notifications. |
Vehicle data related to vehicle performance, usage, operation, and condition: Interior temperature, air conditioning settings, air quality information, speed information, total electric mileage, remaining range, battery remaining capacity, battery voltage, battery current temperature, battery management information, battery charging history, and charging status information. |
To perform our contract with you |
g) Abnormal feedback and product suggestions
|
Purposes |
Types of personal data we use |
Legal Basis |
|
To receive the abnormal conditions of the mobile app you reported or your suggestions for our products |
Account Information: Mobile Phone Number Feedback: detailed descriptions of the issue you submitted, the time when the issue occurred (optional), and images or videos (optional) |
Based on legitimate interests |
|
To help us understand the abnormalities of the mobile APP and their causes |
Log Information: Vehicle Identification Number (VIN), vehicle version number, phone model, APP version number, and phone system version |
Based on your consent |
h) System permissions
To utilise the aforementioned app features, we request the following app permissions from you:
|
Permission Type |
Corresponding Vehicle Function |
System （iOS/Android） |
|
Read and write storage permissions |
To ensure the stable operation of our app upon installation, access is only granted to external storage as well as to modify or delete the contents of the SD card. |
Android |
|
Camera permission |
To log in the vehicle’s account using the scan feature. For you to upload photos or videos when providing feedback on mobile anomalies or product suggestions. |
iOS、Android |
|
Photo album permission |
To choose photos from your album and sue the scan feature. For you to upload photos or videos when providing feedback on mobile anomalies or product suggestions. |
iOS、Android |
|
Geolocation permission |
To determine the GPS information of the mobile phone for vehicle locating service. |
iOS、Android |
|
Bluetooth permission |
To provide you with Bluetooth key service, and link Bluetooth with the vehicle for information transmission. |
iOS、Android |
|
Network permission |
To provide you with networking service for the application, and access to the network or modification of network settings. |
iOS、Android |
|
Notification permission |
To use the front desk service with Bluetooth key, and follow the system settings to allow your phone to receive notifications. |
Android |
We may disclose your personal data to the following receipts who process the data in accordance with the purposes under this Policy. These third parties may be located in Thailand and areas outside Thailand. We will implement reasonable steps to ensure the protection of your personal data, such as confidentiality arrangements, encryption, or appropriate security measures to the extent as required by law.
|
Recipient |
Purpose |
|
Affiliated Companies of Changan |
As we are part of the companies in Changan Group, we may collaborate and utilize shared functions in providing products and services to you. |
|
Our authorized dealers |
We may share and receive your personal data from our authorized dealers and car service centres that you choose or that are near you to provide services to you. |
|
Our services providers |
We may share your personal data with the services providers to offer you various services on our behalf or to help to provide services to you, including but not limited to emergency roadside assistance service providers, IT system, IT support and data hosting providers, companies that provide marketing and communication services. |
|
Our business partners |
We may share your personal data with insurance business, financial institutions, and our external advisors, lawyers, auditors. |
|
Legal authorities |
In some cases, we may have to disclose your personal data in order to comply with the laws and regulations, including compliance with the law enforcement agencies, courts, competent officials, government offices or other third parties in the event that we believe we need to comply with the legal duties or regulations or need to protect our rights, rights of others or the safety of people or to investigate, prevent or manage fraud, stability or security issues. |
|
Assignee of rights obligations |
We may transfer your personal data in the event of a merger, acquisition, or bankruptcy. |
We will retain personal data for as long as necessary to fulfill the purposes outlined in this Policy and to comply with our legal obligations. After the personal data is no longer needed or no law is available to enforce the collection, we will delete or destroy the data. The data retention periods may vary depending on the personal data collection objectives. In the event of a judicial or disciplinary action, your personal data may be stored until the end of such action, including any potential period for appeal, and will then be deleted or archived as permitted by applicable laws.
We implement various measures to safeguard your personal data from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure. These measures include controlling and limiting access to personal data and the use of devices that store and process it. We also establish measures for retrospective review of access, change, deletion, and transfer of personal data. Our security measures cover administrative, technical, and physical safeguards to protect the confidentiality, integrity, and availability of personal data in compliance with applicable laws.
We manage a global business and may transfer the personal data collected from you to our overseas related entities for the purposes outlined in this policy. It may be necessary for us to disclose your personal data to third parties located overseas in connection with the purposes set out in this Policy. The countries to which we may transfer your personal data to Singapore.
We may transfer your personal data to other countries outside Thailand with your consent or as required by law that allows us to pursue our legitimate interests, to the extent permitted by applicable laws. If we are obligated to obtain your consent for transferring your personal data to third parties outside the country, and the receiving country may have inadequate personal data protection standards according to the laws in Thailand, we will take necessary actions to protect your transferred personal data in line with the personal data protection standards we adhere to, as stipulated by the applicable personal data protection laws at that time.
To exercise your rights regarding your personal data, you can contact the us using the contact details provided in 9. Our contact details section.
When making a request, please specify which right you are exercising and which data it concerns. Note that your rights are not absolute and may be withheld in accordance with applicable data protection laws. If your request is rejected, you will be informed of the reasons for doing so. We will process your request as soon as possible and provide you with information on actions taken within thirty days of receiving your request.
a) Your right to access data
You have the right to access or request a copy of the personal data we are collecting, using and disclosing about you. You can check your login password, mobile number and security code through "Personal Centre" - "Account and Security". In addition, you can check the information of your vehicle through "Personal Centre" - "Vehicle Management".
b) Your right to rectification data
You have the right to request for rectification of the incomplete, inaccurate, misleading, or not up-to-date personal data that we collect, use, and disclose. You can modify your login password, mobile number and security code through "Personal Centre" - "Account and Security".
c) Your right to delete your account
You may apply to cancel your account through the APP by navigating to "Personal Centre" - "Account and Security" -"Cancel Account", or by contacting us via the contact details listed in section 9 of our Privacy Policy. We will assist you with the account cancellation process after verifying your identity.
Should you opt to cancel your account, we will delete or anonymize your personal data in accordance with legal and regulatory requirements, except where otherwise stipulated by laws and regulations. Upon the cancellation of your account, we will no longer be able to provide you with account registration services and products or services that require account login.
Please note that to safeguard your vehicle and account security, you will temporarily be unable to cancel your account if it is linked to any CHANGAN vehicles other than the Avatr brand. If you wish to cancel your account, please first unbind these vehicles and then proceed with the account cancellation process. Once your account is successfully cancelled, any accounts linked to your vehicle will automatically be logged out.
d) Your right to erasure data
You can request the deletion or destroy of your personal data in the following cases:
1. When the personal data are no longer necessary for the purposes of collection or use, for example, when you delete your account.
2. When you have withdrawn your consent for the collection, use, and disclosure of the personal data, and there is no legal basis for further collection or use.
3. When you have objected to the further collection or use of the personal data, and there are no valid legal exceptions to reject the objection.
4. When the personal data have been collected, used, and disclosed illegally.
It is important to note that there are legal exceptions, such as collecting for the purpose of contract performance or establishing legal claims, where the right to request erasure of personal data may not apply.
e) Your right to object
You can request the object the collection, use or disclosure of your personal data in the following cases:
1. The collection, use or disclosure of your personal data can be demonstrated by us that there’s a compelling legitimate ground.
2. The collection, use or disclosure of your personal data is carried out for the establishment, compliance or exercise of legal claims, or defense of legal claims.
3. The collection, use or disclosure of your personal data is for the purpose of direct marketing.
4. The collection, use or disclosure of your personal data for the purpose of scientific, historical or statistic research, unless it is necessary to performance of a task carried out for reasons of public interest by us.
If you exercise the right to object the collection, use or disclosure of such personal data, you can also request us to delete them or restrict such use.
f) Your right to restrict use
You can request the restrict use of your personal data in the following cases:
1. When we are pending examination process in accordance with your data subject rights.
2. When it is the personal data which shall be erased or destroy, but you request the restriction of the use of such personal data instead.
3. When it is no longer necessary to retain your personal data for the purposed of such collection, but you have necessity to request for further retention for the purpose of the establishment, compliance or exercise of legal claims, or defense of legal claims.
4. You have objected to the collection, use or disclosure of your personal data based or with citation on scientific, historical or statistical research.
g) Your right to withdraw consent
You have the right to withdraw your consent, but each business function requires some basic personal data to be completed. In cases where a service relies on your authorization to be realized or function normally, if you withdraw the relevant authorization, we will not be able to continue to provide you with the corresponding service or some functions of the service will be affected. Your withdrawal of consent will not affect the personal data that you have already agreed to collect, use, or disclose. If you opt-out of receiving promotional communications, we may still send you non-promotional communications related to your vehicle or our business relationship. You can withdraw or change your authorization through the following methods:
1. You can turn off the relevant device permissions (including location, photos, notifications, etc.) through the "Mobile - System Settings" function on your device, withdrawing authorization for us to access your personal data;
2. Contact us through the contact details disclosed in section 9. Our contact details of this privacy policy.
You have the right to withdraw your consent for the collection, use, or disclosure of your personal data, except in cases where the law or our contractual obligations prevent such withdrawal. Withdrawing your consent will not affect the personal data that you have already consented to be collected, used, or disclosed. If you opt out of receiving promotional communications, we may still send you non-promotional communications related to your vehicle or our ongoing business relations.
h）Your right to data portability
The right to data portability allows you to obtain your personal data from a data controller in a structured, electronic format, and to send or transfer such personal data to another data controller, where this personal data which you have provided to the data controller, and if the data controller is collecting, using and disclosing such personal data on the basis of your consent or to perform a contract with you.
However, we may not have the automated means to provide a copy of your data to other data controllers at present. Nonetheless, subject to conditions and exceptions under applicable data protection laws, we will review your req uest on a specific case-by-case basis and proceed with your request if all the legal criteria are fully met. This is provided that your personal data that you requested us to port are held by us in the format which is readable or commonly used by ways of automatic machines or tools, and can be used or disclosed by such automatic means to other data controllers. If you wish to exercise your data portability right, you can contact us according to 9. Our contact details section.
i）Your right to lodge complaint with supervisory authority
You have the right to issue complaints about the collection, use, and disclosure of your personal data. If we violate or do not comply with the law, you can make a complaint through our contact methods in 9. Our contact details section, and you may make a complaint to the Thailand Personal Data Protection Committee.
Our vehicle, products, and services do not aim to or intentionally gather any personal data from individuals under the age of 20, quasi-incompetent individuals, or incompetent individuals. If you are a minor, quasi-incompetent, or incompetent person and want to engage with us, you must first obtain consent from your parent or legal guardian before contacting us or sharing your personal data. We do not knowingly collect personal data from minors under the age of 20 without parental consent when required, or from quasi-incompetent or incompetent individuals without the consent of their legal guardian.
We reserve the right to modify or update this Policy in accordance with changes in the use of your personal data and applicable laws. We will notify you of any substantial changes or any legally required changes that are substantial to this Policy via updates of the App and obtain your consent if consent is required.
If you have any questions, concerns or complaints about how we collect, use or disclose of your personal data, or if you believe that we have not complied with this Policy, please contact us. We take all complaints seriously and will assess them efficiently. We request that you cooperate with us during this process and provide us with any relevant information that we may need. If you are not satisfied with the outcome of our assessment of your complaint, you may contact the Thailand Personal Data Protection Committee.
If you have questions or concerns regarding our use of your personal data, or would like to exercise any of your rights, please contact us. Our details are as follows:
Company Name: CHANGAN Auto Sales (Thailand) Co., Ltd.
Company Mailing Address: Rooms 7E1-16 and 8E1-16, 7th and 8th floors, Parq Building, 88 Ratchadaphisek Road, Khlong Toei Sub-district, Khlong Toei District, Bangkok City, Thailand, 10110
Email Address of the Data Protection Officer ("DPO"): compliance@changan.co.th