- LEGAL INFORMATION
Data controller: Engine Analytics, legal address: 7 Soi Chan 51 Yeak 10, Watprayakrai Sub-district, Bangkholaem District, Bangkok 10120, Thailand
Contact information: e-mail address: firstname.lastname@example.org
- DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data) – Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data – Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User – The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject – The natural person to whom the Personal Data refers.
Data Controller (or Owner) – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
- COLLECTING OF DATA
This section explains generally the sources from which, and the means by which, we collect and process personal information.
- Order our Services
When you order our services, your contact information, payment information, identification information will be used to process your order and deliver our services.
- Join our mailing list
When you subscribe to our mailing list, your e-mail address will be used to send updates, news and other commercial information.
- Contact us
If you contact us in relation to any of the Services (via email), We may collect and retain your contact details and your communication for the purpose of handling your query and keeping records of communications.
- Other Means of Collection. We collect personal information by a variety of means and methods, including the following:
- When you submit personal information to us voluntarily, communicate with us, pay for our services which may appear on our Website, or use any of our Services;
- When you visit our Website, we may collect location and other information from the internet browser you are using;
- When your communications with us provide us with certain technical formation, such as internet protocol (IP) address, browser type, time zone setting and location, device operating system, and other technologies you may use to access our Website or otherwise communicate with us;
- From third parties and public sources, including from data analytics providers for our own social media pages, like Facebook, Twitter, Instagram;
- COLLECTED DATA
The personal information we collect varies by user, transaction, and purpose, but our primary purpose is the efficient and satisfactory conduct of our business and for related legal purposes.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as contacting the User and sending emails using mailing list. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Generally, we collect the following data:
- Information User provides when communicating using our Website, register an account or order our products;
- Information we obtain from a third party, such as a site or website provider, about use of our Website on third-party websites or devices;
- Location information, including location information provided by a mobile or other device interacting with our Website (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
- Activity information about your use, and the use by any person(s) you authorize through your account on our Website, such as the services you provide, how often you use our services, and your preferences; and
- Usage, viewing, technical, and device data when you visit our Website on third-party sites or websites, or open emails we send, including your browser or device type, unique device identifier, and IP address
We collect the following categories of Personal data for the following activities:
|Activity||Categories of Personal data|
|Visiting the Website||• Browsing data.
• Device information.
|Contacting our support teams||• Identification data.
• Contact data (e-mail address).
• Content of your request.
|Allowing the visitors and Users to exercise their data protection rights||• Identification data.
• Contact data.
• Content of the request.
• Data necessary to reply to the request.
|Complying with legal requests or manage litigation||• Data necessary to prove our compliance to its obligations and/or manage legal proceedings.|
|Order our services||• Identification information;
• Payment information;
• Contact information;
- PURPOSE OF DATA COLLECTION
We use the personal information that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:
- To contact you: To contact you by email, telephone calls or other equivalent forms of electronic communication.
- To provide services and process your orders.
- To manage your requests: To attend and manage your requests to us.
- To respond to your requests and questions, resolve disputes, investigate and address your concerns, and monitor and improve our responses;
- For testing, research, analysis, and a product and service development, including to improve our Website and services;
- For facilitating and processing your transactions with us and with our third party affiliates and business partners, if we choose to provide these services;
- To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations;
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, marketing and your experience.
- METHODS OF DATA PROCESSING
Engine Analytics takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Engine Analytics, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Engine Analytics. The updated list of these parties may be requested from the Owner at any time.
- TRANSFERS AND SHARING OF DATA
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Engine Analytics using the information provided in the contact section.
Engine Analytics may store, process your personal data outside the European Union (EU)/European Economic Area (EEA). In this case, your personal data is processed in United States of America.
We may share your personal data with following recipients:
- Internal recipients – your Personal data will only be disclosed to authorize employees that require an access to fulfil their obligations (e.g. support teams, developers, etc.). Our employees are specifically trained and made aware of the sensitivity of your Personal data and the requirements necessary to ensure the protection of your right to privacy.
- Processors – in order to provide the Services, Engine Analytics may communicate your Personal data to other entities acting as data processors.
- Partners and third parties – in order to provide the Services, Engine Analytics may communicate your Personal data to third party service providers.
- Judicial, administrative and other public authorities – Engine Analytics may have to share or disclose some of your Personal data if it is required to do so by the law, by a request meaning from a competent authority., to comply with a court order, to obtain legal remedies or defend Engine Analytics’s rights, to contribute with investigations (e.g. fraud, identity theft, etc.).
- RETENTION TIME
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Personal Data collected for the purposes of a Contract between Engine Analytics and User shall be retained as long as there is a Contract between the parties.
- Personal data collected for the purposes of the Consent of the User will be retain for as long as User has given Consent.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
Engine Analytics may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
- RIGHTS UNDER GDPR
Users may exercise certain rights regarding their Data processed by Engine Analytics. In particular, Users have the right to do the following:
- Withdraw consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. If you have unresolved concerns, you have the right to complain to the data protection authority – The Federal Data Protection and Information Commissioner (FDPIC).
Any requests to exercise User rights can be directed to Engine Analytics through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
If user has any issues regarding data processing done by Engine Analytics, user can send request to the national supervisory authority – The Federal Data Protection and Information Commissioner (FDPIC).
Any terms defined in the CCPA that are not otherwise defined in this Supplement shall have the same meanings as such terms are given in the CCPA.
The CCPA provides Users with certain additional rights and information regarding their personal information. This Supplement provides those disclosures and describes those additional rights and explains how such additional rights may be exercised. Please read this Supplement as an expansion of the terms of the Policy set forth above as to Users interacting or doing business with us.
Categories of Personal Information Collected.
Listed below are the categories of personal information that we collect and use in our business for commercial purposes. These categories of data do not all apply at all times or as to all Consumers and often our receipt of this data is based on a Consumer’s voluntary submission of it to us for specific purposes or transactions requested by the Consumer:
|A. Identifiers||A real name, alias, email address or other similar identifiers.|
|B. Internet or other network activity||Online browsing history or other information relating to a Consumer’s interaction with websites, applications, or advertisements.|
|C. Order information||Contact information, identification information, financial information|
Sale of Personal Information.
The CCPA requires that we disclose if we sell the personal information of Consumers to third parties which do not meet the definition of Service Providers under the CCPA. The common understanding of the term “sell” is to transfer property (in this case, personal information) for monetary consideration (i.e., cash), but under the CCPA, the definition of “sell” includes exchanging data for a business benefit other than cash. We do not sell, disclose, or transfer any Consumer’s personal information to a third party which does not meet the definition of Service Providers under the CCPA.
California Residents’ Rights
We extend the following rights to Users relating to their personal information that we have collected, used, or hold (collectively, “Data Rights”).
When Data Rights Do Not Apply. Data Rights are subject to certain exceptions and limitations based on the specific data processing activities involved or other legal constraints like law enforcement and litigation uses. If any of those exceptions or limitations should apply to a Data Rights request, we will explain in our response why (or the extent to which) we are unable to honour a User request.
Data Rights Described. A User’s rights relating to his or her personal information includes one or more of the following rights if and as applicable to a given request (a “Data Rights Request”).
The Right to Know. A User has a right to request that we disclose certain information to him or her about our collection and use of the User’s personal information over the past 12 months. Upon such a request, after verification of the User’s identity, we will confirm (i) the categories of personal information we have collected about the User, (ii) the categories of sources from which such information was collected, (iii) the business or commercial purpose for our collection, disclosure or use of such data, (iv) the categories of any third parties with which we shared such personal information for a business purpose, and (v) the specific pieces of personal information we have collected about the User.
The Right of Deletion. In some circumstances, a User has the right to request that we delete personal information that we have collected from or about the User. Those circumstances include when (i) the personal information is no longer necessary in relation to the purposes for which it was collected or processed; (ii) the User withdraws his or her consent to any consent-based processing such as marketing; and/or (iii) our continued processing of such data violates this Policy or is otherwise unlawful. However, there are exceptions to the right of deletion, including when our retention and processing of such data is reasonably necessary to (A) complete the transaction for which such data was collected, to fulfil the terms of a written warranty or product recall or otherwise perform our contract with the User, (B) provide a product or service requested by the User or take actions reasonably anticipated within the context of our ongoing business relationship, (C) detect security incidents or protect against deceptive, fraudulent or unlawful activity, (D) for internal use reasonably aligned with the User’s expectations under this Policy or applicable law, and/or (E) compliance with a legal obligation.
The Right to Data Portability. In certain circumstances under the Right to Know, a User has the right to access the specific pieces of his or her personal information that we collected from such User, by mail or electronically, and if provided electronically, in a portable, readily useable format to the extent technically feasible. However, this right does not apply where it is outweighed by other lawful needs or when the attempted return of it would adversely affect the rights or interests of others, such as when the personal information cannot be segregated from other protected data.
Right to Opt-Out of the Sale of Personal Information. If and to the extent we are deemed to Sell a User’s personal information to a third party, the User has the right to direct us to stop Selling the User’s personal information to such third parties (the “Right to Opt-Out”). To exercise the Right to Opt-Out, the User may submit a Data Rights Request Form to us invoking such right. The Consumer does not need to create an account with us to exercise his or her Right to Opt-Out. We will only use personal information provided in an opt-out request to review and comply with the requesting User’s request. A User’s exercise of the Right to Opt-Out will only apply to our disclosures to third parties which are not Service Providers and will not affect our own communications and transactions with our User or communications by our business partners with our Users in connection with our own business activities.
To exercise any Data Rights contact us or by:
- Emailing us at email@example.com
Any Data Rights Request must:
- Provide sufficient information to permit us to reasonably verify that the requestor is the person about whom we collected personal information or an authorized representative thereof. We cannot respond to a request or provide personal information if we cannot verify the requestor’s identity or authority to make the request and confirm that the personal information relates to them.
- Such verification requirements include proof of the identity of the User about whom a request is made either (i) by a third party identity verification service engaged by us, or (ii) by our matching the identifying information of the User at issue with the personal information of the User already maintained by us, either in a password protected account with the User or by identification of the User’s recent vehicle searches or other activities with us or our business partners.
- Describe the Data Rights Request with sufficient detail for us to properly understand, evaluate and respond to it.
Users do not need to create an account with us to submit a Data Rights Request, but we do consider requests made through a password protected account sufficiently verified when the request relates to personal information associated with that account. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
We will promptly confirm receipt of any such request (generally within ten 10 days) and endeavour to substantively respond to it after verification within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically or as otherwise agreed.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to verifiable Data Rights Requests unless excessive, repetitive, or manifestly unfounded.
Authorized Agent: The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Should the changes affect processing activities on the basis of the User’s consent, Engine Analytics shall collect new consent from the User, where required.
Latest update: January __, 2023