Privacy Policy

    1. This Privacy Policy explains how Lao Smart Mobility Co., Ltd (referred to as “Company,” “we,” “us,” or “our”) collects, uses, discloses, and processes Personal Data when you use our application(including KOKKOK Car), websites, and services(collectively, the “App”).

    2. Please read this Privacy Policy carefully before using our services. By using our services, you(“you,” “your,” or “yours”) agree to the collection, use, and transfer of your information as described in this policy.

    1. I. COLLECTION OF PERSONAL DATA

        1. Collection of Personal Data

          The company collects personal data for registration, 1:1 inquiries, and the provision of various services.

          RegistrationTypeCollection of dataCollection and Operation Purpose
          Personal CustomerEssentialName, Password, UUID, Contact Number(Phone number), Email, Date of Birth
          1. Contract Performance for Service Provision and Fee Settlement
          2. • Content provision, identity verification, purchase and payment processing, and fee collection.
          3. Customer Management
          4. • Customer service use, limited self-verification, personal identification, prevention of fraudulent and unauthorized use, registration management, dispute resolution, complaint handling, notifications, and prevention of underage registration (under 14 years old).
          5. New Service Development and Marketing
          6. • Development of new services, provision of customized services, service validity verification, access frequency tracking, and user statistics analysis.
          OptionalGender
          Mobile CustomerEssentialAPP ID, Push IDKOKKOK Car APP notification
          Sales (Used Car)EssentialName, UUID, Contact Number, Brand, Model, Car Type, MileageCustomer identity verification and vehicle information verification
          Test Drive (Used Car)EssentialName, UUID, Contact Number, Email, Date of Birth, GenderCustomer identity verification

          It is collected data of a specific type related to the customer's interests or event-related information.

          Additionally, created data from the service usage process or business handling process is collected/used as follows:

          Browser Type and OS, Device Information (Model Name), Search Item, Service Usage Records: Used for statistical analysis of service usage and error analysis by device type.
          IP Address, Visit Date and Time, Service Usage History, Bad Usage History, Cookie: Used for tracking and analyzing service usage patterns.
          Payment Records: Retained as electronic transaction records.
          Consultation Records: Used for handling inquiries and complaints.

          The company collects only the minimum amount of personal data necessary to provide the service and does not collect sensitive information that may infringe on the user's basic rights (such as race, religion, ideology, place of origin, birthplace, political inclination, criminal records, health status, etc.), except with user consent.

          Customers can refuse to consent to the collection/use of personal data. However, this may limit service usage and benefits. Refusing consent during membership registration may restrict service provision.

          1. Non-Members

            2. For non-member services, only the personal data necessary for each specific service is requested. This data is used solely for service-related purposes and not for other uses. Non-members’ data is protected to the same extent as members' data, except where specific member-only policies apply.

          2. Automatically Generated Personal Information

            3. Includes data related to the customer's interests, collected through events or additional data collection efforts:

            Browser Type and OS, Device Information (Model Name), Search Item, Service Usage Records: Used for statistical and error analysis.
            IP Address, Visit Date and Time, Service Usage History, Bad Usage History, Cookie: Used for service usage analysis.
            The company ensures that only the necessary personal data is collected, avoiding sensitive information unless explicitly consented to by the user.

            Customers can refuse to consent to personal data collection/use. However, this may result in restrictions on service usage and benefits. Refusal to consent to essential information during membership registration will limit service provision.

        2. Methods of Collecting Personal Data

        The company collects personal data through the following lawful and fair methods:

        • Online: Via the website, through 1:1 inquiries, email, and event entries (with consent for the use of name and contact information).
        • Consultations: Through the customer center via email, fax, phone, chat, and remote consultations.
        • Third-Party Providers: Through provision by partner companies.
        • Data Generation Tools: Collection through tools that generate information during service usage.
        • Offline Methods: Through branch staff during service applications.

    2. II. USE OF PERSONAL DATA

        We may use your Personal Data for the purposes listed below ("Purposes"). Additionally, if you use our app in various capacities (for example, if you use multiple KOKKOK Car services, or if you are both a customer and service provider/employee), we may link your Personal Data collected across your various roles to facilitate your use and for the Purposes described below:

        1. Providing Services and Features

        1. Your Personal Data will be used to provide, personalize, maintain, and improve our app. This includes using your Personal Data to:

          1. Engage you in providing services across our various business verticals.
          2. Identify and register you, and administer, deactivate, or manage your account.
          3. Process, manage, or verify your eligibility for or application of services, promotions, and rewards with our app.
          4. Conduct due diligence checks and risk assessments/analysis.
          5. Verify your identity and age, where necessary.
          6. Process payments.
          7. Personalize your app experience, such as recommending products and services relevant to you, identifying your preferences, or otherwise personalizing your experience with our app.
          8. Perform internal operations necessary to provide our services, including troubleshooting software bugs and operational problems, conducting data analysis, testing, and research, and monitoring and analyzing usage and activity trends.
          9. Protect the security or integrity of the services and any facilities or equipment used to make the services available.

        2. Safety and Security

        1. We use your data to ensure the safety and security of our services and all users. This includes:

          1. Screening service providers/employees before enabling their use of our services.
          2. Verifying your identity when you log in to KOKKOK Car.
          3. Using device, location, profile, usage, and other Personal Data to prevent, detect, and combat fraud or unsafe activities.
          4. Sharing the location and details of service providers/employees when they accept a customer's request and then pick up the goods or customer.
          5. Monitoring compliance with our terms of service and policies.

        3. User Support

        1. We use Personal Data to resolve customers’ support issues. For example, we may:

          1. Investigate and address concerns.
          2. Monitor and improve your support responses.
          3. Respond to questions, comments, and feedback.
          4. Inform you about steps taken to resolve customers’ support issues.

        4. Research and Development and Security

        1. We may use the Personal Data we collect for testing, research, analysis, and product development. This allows us to understand and analyze your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our services, develop new features, products, and services, and facilitate the development of insurance and finance solutions.

        5. Legal Purposes

        1. We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.
        2. We may also use your Personal Data when we are required, advised, recommended, expected, or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental, or other authority.

        3. For example, we may use your Personal Data to:

          1. Comply with court orders or other legal, governmental, or regulatory requirements.
          2. Enforce our Terms of Service or other agreements.
          3. Protect our rights or property in the event of a claim or dispute.

        6. Marketing and Promotions

        1. We may use your Personal Data to send you marketing communications relating to customized products or services (that may be of interest or relevance based on your profile), or those of our partners, sponsors, and advertisers. For example, we may:

          1. Send you special offers that may be of interest or relevance to you across all of KOKKOK Car’s service offerings.
          2. Send you alerts, newsletters, updates, mailers, promotional materials, special privileges, and festive greetings.
          3. Notify, invite, and manage your participation in our events or activities.
        2. We may communicate such marketing to you by various means, where applicable (including by SMS, WhatsApp, Facebook, push notification, call, and email).
        3. If you wish to unsubscribe from receiving such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may update your preferences in our app's settings. Please note that while you may opt out of marketing or promotion information, we may still send you service-related messages (such as information on your transactions, rewards, etc.).

    3. III. DISCLOSURE OF PERSONAL DATA

        We may need to share Personal Data with various parties for the purposes outlined in this policy. These parties include:

        1. With Third Parties

        1. We use users' personal information within the scope notified in "I. COLLECTION OF PERSONAL DATA" and do not disclose customer's personal data to external parties without prior consent from the user, except in the following cases:

          1. If the customer has given prior consent to the disclosure or if it is necessary to fulfill a service-related contract, particularly when obtaining ordinary consent is significantly difficult due to economic or technical reasons.
          2. If the company believes in good faith that disclosure is required by law, such as in response to a lawful request by government or investigative authorities according to relevant laws and regulations.
          3. If the user's personal information is provided to a third party for purposes necessary for the use of the service, with separate confirmation of the user's consent.

        2. With Our Business Partners

        1. We may provide Personal Data to our consultants, marketing partners, research firms, and other service providers or business partners, which include:

          1. Payment processors and facilitators.
          2. Debt collectors.
          3. Credit bureaus, alternative credit scoring agencies, and other credit reporting organizations.
          4. Background check and anti-money laundering service providers.
          5. Cloud storage providers.
          6. Advertising and marketing partners and platform providers.
          7. Data analytics providers.
          8. Educational and training institute partners.
          9. Insurance and financing partners.
          10. Service providers who perform identity verification services.

        3. With Our Legal Advisors and Governmental Authorities

        1. We may share your Personal Data with our legal advisors, law enforcement officials, government authorities, and other third parties. This may take place to fulfill the legal purposes (mentioned above), or in any of the following circumstances:

          1. Where it is necessary to respond to an emergency that threatens the life, health, or safety of a person.
          2. Where it is necessary in the public interest (e.g., in a public health crisis, for contact tracing purposes, and safeguarding our community).

        4. Business Transfers

        1. We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing, or any other type of business transactions. Your Personal Data will, however, remain subject to our obligations made in any pre-existing Privacy Policy that you have agreed to.

    4. IV. RETENTION OF PERSONAL DATA

        We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Once your Personal Data is no longer necessary for the services or purposes described, or we no longer have a legal or business reason to retain it, we take steps to erase, destroy, anonymize, or prevent access or use of such Personal Data. These actions are taken for any purpose other than compliance with this Privacy Policy, or for purposes of safety, security, fraud prevention, and detection, in accordance with the requirements of applicable laws.

    5. V. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

        1. Cookies

        1. We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers, and similar technologies (collectively, "Cookies") in connection with your use of our app. These Cookies may be persistent or stored only during an individual session on your browsers or devices.

        2. Cookies may have unique identifiers and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. They may be used for various purposes such as to:

          1. Provide the essential, basic functions of using our app.
          2. Authenticate you or remember your user preferences and settings.
          3. Deliver and measure the effectiveness of advertising campaigns, for example, by measuring the number of views or click-throughs.
          4. Analyze site traffic and trends.
          5. Serve you relevant advertisements across other apps and websites owned by other companies (whether by us or other advertisers).
          6. Enhance the user interface and experience by generally understanding the online behaviors and interests of users who interact with our app.
        3. We may allow third parties to use Cookies on our websites and apps to collect the same type of Personal Data for the same purposes we do for ourselves. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

        2. Disabling the Collection of Cookies on Our Website

        1. You have the right to choose to disable, block, or deactivate cookies. Please note, however, that the refusal or removal of some cookies could affect the availability, functionality, or usage of our app.
        2. You may adjust your internet browser settings to disable, block, or deactivate cookies, delete your browsing history, or clear the cache from your internet browser. The settings may be contained within the "History," "Preferences," "Settings," or "Privacy" sections of your internet browsers, or you may otherwise consult the help section of your internet browser for more information.

    6. VI. PROTECTION OF PERSONAL DATA

        We will take reasonable legal, organizational, and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or being used or accessed in an unauthorized manner. We limit access to your Personal Data to our employees on a need-to-know basis. Those processing your Personal Data will only do so in an authorized manner and are required to treat your information with confidentiality.

        Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means; therefore, any transmission remains at your own risk.

    7. VII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

        In accordance with applicable laws and regulations, you may be entitled to:

          1. Inquire about the processing of your Personal Data and be provided with a copy of it;
          2. In some cases, request the correction and/or deletion of your Personal Data;
          3. In some cases, request the restriction of or object to the processing of your Personal Data;
          4. Withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
          5. Request receipt or transmission to another organization, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract;
          6. Complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.

          Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

          However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it, or to your agreement with our Privacy Policy could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of our app.

          After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

          We will screen and verify all requests beforehand. In order to verify your identity and/or authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

      1. VIII. AMENDMENTS AND UPDATES

        We may modify, update, or amend the terms in this Privacy Policy at any time. Such amendments will be notified to you through the app and/or other appropriate means at least seven (7) business days before the effective date. The updated version will be posted on our website at https://laosmartmobility.com. It is your responsibility to regularly review the Privacy Policy. Your continued use of our app, or continuing to communicate or engage with us following the effective date of the modifications, updates, or amendments to this Privacy Policy, whether or not reviewed by you, will constitute your agreement to be bound by such amendments.

      2. IX. HOW TO CONTACT US

          If you have any queries about this Privacy Policy or would like to exercise your rights set out in this Policy, please direct your correspondence to our Data Protection Officer:

          E-mail: contact@laosmartmobility.com

          Name: Lao Smart Mobility Co., Ltd (Attention: Lao Smart Mobility Privacy Office) Address: Asean

          Road (T2), Nongdouang Village, Sikhottabong District, Vientiane Capital, Lao PDR

          The original of this notice is written in English. In the event of any conflict between the English and other language versions, the English version shall prevail.

          The latest update date: September 30th, 2024.