Öhlins Asia Co., Ltd (“Öhlins,” “we,” “us,” or “our”) recognises the importance of the protection of Personal Data which is any information relating to an identified or identifiable natural person. The high standards you expect from our products and services are our guideline for handling your data which may include the collection, use, disclosure, and/or transfer outside of Thailand. Our aim is to create and maintain the basis for a trusting business relationship with our customers and prospects. The confidentiality and integrity of your personal data is top priority for us.
This privacy policy ("Privacy Policy") applies to our Öhlins Community activities, and associated Landing Pages, Surveys and Newsletter Subscriptions, whether directed to from Social Media or event QR code links where we collect your Personal Data. However, please read this Privacy Policy in conjunction with the terms and conditions of the particular service that you use.
We reserve the right to modify this Privacy Policy at time to time, so please review it frequently to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our website or application. We will provide additional notice of significant updates.
1. What Personal Data we collect
We may collect or obtain the following types of information which may include your Personal Data directly or indirectly from you or other sources or through our affiliates, subsidiaries, other companies, or business partners. The specific type of data collected will depend on the context of your interactions with us.
(1.1) Personal details, such as full name, gender, age, nationality, date of birth, preferred language, personal interests, brand awareness, vehicle ownership and vehicle suspension;
(1.2) Contact details, such as telephone number, email address, LINE ID, Facebook account, Instagram ID, and other ID from social networking sites;
(1.3) Vehicle details, such as vehicle type, model, model year and suspension fitted;
(1.4) Technical details, such as Internet Protocol (IP) address;
(1.5) Behaviour details, such as information about your interests and vehicle use;
(1.6) Profile details, such as your interests, preferences, feedback and satisfaction survey responses;
(1.7) Marketing and communication details, such as your preference in receiving marketing from us, our affiliates, subsidiaries, business partners, and your communication preferences; and/or
(1.8) Other information that Öhlins Asia Co., Ltd collected, used or disclosed in connection with our relationship, such as an application form or survey. We will only collect, use, or disclose sensitive data on the basis of your explicit consent or where permitted by law. We do not knowingly collect information from customers under the age of 20 without their parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardian's consent. In the event we learn that we have unintentionally collected personal information from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardians, we will delete it immediately or process only if we can rely on other legal bases apart from consent.
2. Why we collect, use and/or disclose your Personal Data and the purpose of which you have given your consent:
(2.1) Marketing and Communications: To provide marketing, re-marketing, re-targeting, segmentation, communications, sales, special offers, promotions, notices, news, information about other products and services from Öhlins Asia Co., Ltd, our affiliates, subsidiaries and/or business partners which we cannot rely on other legal bases;
We may collect, use, and/or disclose your Personal Data for the following purposes:
(2.2) To provide products and services to you: To provide aftersales services;
(2.3) Marketing and Communications: To provide marketing, re-marketing, re-targeting, segmentation, communications, sales, special offers, promotions, notices, news, information about other products and services from Öhlins Asia Co., Ltd, our affiliates, subsidiaries and/or business partners in accordance with preferences you have expressed directly or indirectly;
(2.4) Participating in contests, prize draws and similar promotion: To allow you to participate to promotions, special offers, privilege, lucky draws, and other offers/promotions (e.g. for sending you reminder emails, transferring your Personal Data to fulfilment partners), technical campaign, activities, events and seminars, re-marketing, re-targeting and all related advertising services; to process and administer your account registration, gift registration, and event registration; to examine your entire user history, both online and offline;
(2.5) Recommendations and Personalisation: To recommend products and services that might be of interest to you, identify your preferences, and personalise your experience;
(2.6) Registration and Authentication: To register, verify, identify, and authenticate you or your identity;
(2.7) To contact and communicate with you: To provide you with marketing communications, sales, special offers, promotions, notices, news, and information about the products and services; to process and update your information;
(2.8) To manage our relationship with you: To communicate with you in relation to the products and services you obtain from us, our affiliates, subsidiaries, and from our business partners; to process and update your information as our member; to facilitate your use of the products and services; to handle customer service-related queries, request, feedback, complaints, warranty claims, disputes or indemnity; to deal with technical issues, provide technical assistance, repairs, warranty and goodwill; to conduct customer relationship management activities (e.g., customer satisfaction index survey);
(2.9) Profiling and data analytics: To measure your engagement with the products and services; to undertake data analytics for products and services development, market research, surveys, assessments, behaviour, statistics and segmentation, consumption trends and patterns; to know you better; to improve business performance and better adapt our content to the identified preferences of our customers; to determine the effectiveness of our promotional campaigns; to identify and resolve of issues with existing products and services, and qualitative information development;
(2.10) To improve business operations, products, and services: To evaluate, develop, manage, improve, research and develop the services, products, system, and business operations for you and all of our customers and Öhlins Asia, including but not limited to, our business partners; to measure the performance of our physical products, digital properties, and marketing campaigns; to conduct a lead generation and sales funnel management; to assure products and service quality; to conduct a legal consulting; to create aggregated and anonymised reports; to identify and resolve issues; to provide training courses for sales personnel; to improve the request and sales process;
(2.11) To learn more about you: To learn more about the products and services you receive, and other products and services you may be interested in receiving, including profiling based on the processing of your Personal Data, for example, by looking at the types of products and services that you use from us, how you like to be contacted and so on; to learn from the satisfaction survey and customer credit evaluation;
(2.12) Functioning of our platform: To administer, operate, track, monitor, and manage our Landing Pages to facilitate and ensure that they function properly, efficiently, and securely; to facilitate your experience on our Landing Pages and platform; improve layout, and content of our sites and platform;
(2.13) IT Management: For our own business management purpose including for our IT operations, management of communication system, operation of IT security and IT security audit; internal business management for internal compliance requirements, policies, and procedures;
(2.14) Compliance with regulatory and compliance obligations: To comply with legal obligations, legal proceedings, or government authorities' orders which can include orders from government authorities outside Thailand, and/or cooperate with court, regulators, government authorities, and law enforcement bodies when we reasonably believe we are legally required to do so, and when disclosing your Personal Data is strictly necessary to comply with the said legal obligations, proceedings, or government orders; to record and monitor communications;
(2.15) Protection of our interests: To protect the security and integrity of our business; to exercise our rights or protect our interest where it is necessary and lawfully to do so, for example, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law; to manage and prevent loss of our assets and property; to secure the compliance of our terms and conditions;
(2.16) Fraud detection: To verify your identity, and to conduct legal and other regulatory compliance checks. This includes to perform internal audits and records, asset management, fraud database, system, and other business controls;
(2.17) Corporate transaction: in the event of sale, transfer, merger, reorganisation, or similar event we may transfer your information to one or more third parties as part of that transaction;
3. To whom we may disclose or transfer your Personal Data
We may disclose or transfer your Personal Data to the following third parties who collects, uses and discloses Personal Data in accordance with the purpose under this Policy. These third parties may be located in Thailand and areas outside Thailand. You can visit their privacy policy to learn more details on how they collect, use and disclose your Personal Data as you are also subject to their privacy policies.
(3.1) Our service providers
We may use other companies, agents or contractors to perform services on behalf or to assist with the provision of products and services to you. We may share your Personal Data to our service providers or third-party suppliers including, but not limited to (1) internet, software, website developer, digital media, IT service providers and IT maintenance & support company; (2) logistic and courier service providers; (3) payment and payment system service providers; (4) research and market surveillance agencies; (5) analytics service providers; (6) survey agencies; (7) auditors; (8) marketing, advertising media, designer, creative, and communications agencies; (9) call center; (10) campaign, event, and market organisers, and CRM agency; (11) telecommunications and communication service providers; (12) outsourced administrative service providers; (13) data storage and cloud service providers.
In the course of providing such services, the service providers may have access to your Personal Data. However, we will only provide our service providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purposes. We will ensure that the service providers we work with will keep your Personal Data secure as required under the laws.
(3.2) Our business partners
We may transfer your Personal Data to our business partners to conduct business and services related to telecommunications, marketing, retail, wholesale, including platform sellers or providers whom we may jointly offer products or services, or whose products or services may be offered to you.
(3.3) Authorized dealer and sale representative agencies
From time to time, Öhlins Asia Co., Ltd will share and receive Personal Data from the authorised dealer that you choose, or located near you, to serve you with our services.
(3.4) Use of Facebook social plugins on www.ohlinscommunity.com
One of the features of the Öhlins Asia Internet presence on the domain www.ohlinscommunity.com is that it uses what are called social plugins ('plugins') from the social network facebook.com, which are operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ('Facebook'). These plugins are indicated by a Facebook logo. When you access the Öhlins Asia Internet presence on the domain www.ohlinscommunity.com, your browser establishes a direct connection with the Facebook servers. The content of the plugin is transferred by Facebook directly to your browser, which then integrates it into the website. Integration of the plugin causes Facebook to receive the information that you have accessed on the corresponding page of the Öhlins Asia Internet presence. If you are logged in with Facebook, it will be able to assign your visit to your Facebook account. Please note that an exchange of this information already takes place when you visit our Internet presence on the domain www.ohlinscommunity.com, regardless of whether you interact with the plugin or not. If you interact with the plugins, such as by pressing the 'Like' button, the corresponding information is sent directly to Facebook by your browser and saved there. You can find information on the purpose and extent of data acquisition as well as how the data is processed further and used by Facebook, together with your rights and optional settings to protect your private sphere, in the Facebook data protection notes (http://www.facebook.com/policy.php). If you do not want Facebook to gather data about you via our Internet presence, you must log out of Facebook before visiting the Öhlins Asia Internet presence on the domain www.ohlinscommunity.com.
(3.5) Third parties required by law
In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with a legal or regulatory obligations. This includes any law enforcement agency, court, regulator, government authority or other third party where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.
(3.6) Professional advisors
This includes lawyers, technicians and auditors who assist in running our business, and defending or bringing any legal claims.
(3.7) Assignee of rights and/or obligations
Third parties as our assignee, in the event of any reorganisation, merger, business transfer, whether in whole or in part, sale, purchase, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or similar transaction; will comply with this Privacy Policy to respect your Personal Data.
4. International transfers of your Personal Data
We may disclose or transfer your Personal Data to Öhlins Asia, our affiliates, subsidiaries, third parties or servers located overseas, which the Personal Data Protection Committee under the Thai Personal Data Protection Act B.E. 2562 has not ruled that the destination countries have adequate data protection standard. When we transfer your personal data outside Thailand, we will take steps and measures to ensure that your Personal Data is securely transferred and that the receiving parties have in place suitable data protection standards or other derogations as allowed by laws. We will request your consent where consent to cross-border transfer is required by law.
5. How long do we keep your Personal Data
We retain your Personal Data for as long as is reasonably necessary to fulfil purpose for which we obtained it, and to comply with our legal and regulatory obligations. If data is processed for several purposes, the data is deleted automatically or saved in a form that cannot be traced back to you once the last specified purpose has been met. However, we may have to retain your Personal Data for a longer duration, as required by applicable law.
6. Cookies and pixel and how they are used
If you visit our Landing Pages, we will gather certain information automatically from you by using cookies regarding visitor browsing history. A cookie is a small text file which is copied onto your hard disk by a website. Cookies do not cause any damage to your computer and do not contain any viruses. The cookies from our websites do not gather any Personal Data about you. As a rule, cookies are only used on our websites for the length of your session for the purpose of anonymous, statistical assessments and for improving user-friendliness. Cookies may occasionally serve an additional purpose in certain sections of the website. You will be informed of this if you access one of these sections. We also set up pixel which is an analytics tool which we use to understand you more based on your actions that you take on our website. This will help us to know more about you. You can disable cookies and pixel settings by visiting their browser settings and configure privacy settings to restrict any future collection of cookies.
7. Your rights as a data subject
Subject to applicable laws and exceptions thereof, you may have the following rights to:
(7.1) Access: You may have the right to access or request a copy of the Personal Data we are collecting, using and disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you.
(7.2) Rectification: You may have the right to have incomplete, inaccurate, misleading, or not up-to-date Personal Data that we collect, use and disclose about you rectified.
(7.3) Data Portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing such data on the basis of your consent or to perform a contract with you.
(7.4) Objection: You may have the right to object to certain collection, use and disclosure of your Personal Data such as objecting to direct marketing.
(7.5) Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances.
(7.6) Withdraw Consent: For the purposes you have consented to our collecting, using and disclosing of your Personal Data, you have the right to withdraw your consent at any time.
(7.7) Deletion: You may have the right to request that we delete or de-identity Personal Data that we collect, use and disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
(7.8) Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.
(7.9) Our Contact Details
If you wish to contact us to exercise the rights relating to your Personal Data or if you have any queries about your Personal Data under this Privacy Policy, please contact us at: privacy@ohlinscommunity.com
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