Customer Privacy Notice

Nauticomm Company Limited (“We”) who provides the VMS tracking systems (including vessel monitoring system, vehicle tracking system, vessel messaging system and remote monitoring system) both domestically and internationally (collectively referred to as the “Services”) respect the rights of you, our customer (the “you”) relating to your personal data.

We value your trust in providing us your Personal Data, thus we are striving to use commercially acceptable means of protecting it in strict compliance with the applicable laws and the industry standard. But since no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, we may not be able to guarantee its absolute security.

Under this Notice, “Personal Data” means any information that is directly or indirectly identifiable to any specific natural person, including without limitation you individually or your authorized director and/or representatives (the “Representative”).

Acceptance of this Notice

If you choose to use our Service, then we would deem that you agree to the collection and use of the Personal Data as defined under this Notice.

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Amendment of Notice

We reserve the right to review and update this Notice from time to time to ensure that the Notice be in compliance with the relevant laws and regulations and be in accordance with the provision of the Services and we will notify you of the amendment thereof via our communication channels.

Personal Data being Processed

We may obtain the Personal Data from the following sources: (1) directly from you during the communication or coordination; (2) automatically collected upon your visit to our website or upon the activation of our Services; or (3) indirectly from any person; provided that in case of the indirect collection, we will inform you of the source of those Personal Data collections.

We would need to collect, use, and process the following Personal Data:

  1. Contact information including full name as well as contact information of you individually or the Representative (i.e., telephone number, email or address);

  2. Identification information of the you individually or the Representative, for instance, a copy of identification card or passport attached to the agreement;

  3. Your Log Data (i.e., IP address, device name, operating system version, the configuration of the app when using our Services, the time and date of your use of the Services and other statistics) and Cookies (it should be noted that our Services do not use these “cookies” explicitly; however, the app that we use may use third party code and libraries that use “cookies” to collect information and improve their services;

  4. For the use of our Services by any person under your supervision (i.e., employee or driver) (the “User”), the User’s driving license (i.e., truck driver that is required to log-in with their driving license onto our Services); the User’s vehicle information, including the license plates and live position; and User’s own information, including without limitation the facial image collected for the purpose of performance and driving-safe tracking will be collected;

    For the avoidance of doubt, for any processing of any personal data of the User for the performance of the Services, you acknowledge and agree that we are only acting as the “data processor”; therefore, in case you submit any personal data of any related User to us to process, upon the receipt of those personal data, we shall deem that you represent your legitimate rights to share and disclose those personal data to us and therefore we shall be fully entitled to process those personal data pursuant to this Notice and pursuant to the instruction given by you.

  1. Any other Personal Data that may be disclosed or shared during our communication, including without limitation, the complaint or feedback and any payment information such as bank account and reimbursement history of any payment made by and to the individual you.

Objectives of the Personal Data Processing

We need to collect, use and process all the Personal Data (as defined) in order to serve the following purposes:

  1. To provide our Services to you, in particular to communicate and coordinate with you throughout the negotiation and conclusion process of the transaction arrangement with you; to perform any rights and obligations that we may have with you under the agreement entered into, including to perform the Services as defined under the Terms of Services; and to provide any other additional supports as you may require (i.e., to improve the rectify any crash report and diagnosis data);

  2. To perform any of our legal obligation, in particular in the preparation of the accounting and taxation report and the compliance with any other requirements relating to our Services provision;

  3. To protect our legitimate right in 2 main cases: (i) the case that we may need to enforce and protect in the legal proceeding with you; (ii) to improve the good relationship between us, including without limitation to plan the Service improvement for a better experience of you; to manage our risk of fraud and to fix any bug;

  4. To serve any other particular purposes that you may have specific consent to us to process, including without limitation to contact for marketing purposes.

Retention Period of the Personal Data

We would need to retain the Personal Data throughout our Services term; the period of time necessary for us to perform our legal obligations; and for the period of time necessary for the protection of our legitimate rights in the legal proceedings or any other internal business operation purposes.

Disclosure of the Personal Data

Generally, we would not disclose or transfer the Personal Data to third party, except to the following persons: (1) to our third-party service providers engaged to facilitate our Service; to provide the Service on our behalf; to perform Service-related services; or to assist us in analyzing how our Services is used; provided that we shall disclose the Personal Data only on the necessary basis and they are obligated not to disclose or use the Personal Data for any other purpose; and (2) to any government authorities that we may be obliged under the relevant laws or the judgement or order of government authorities to disclose such Personal Data to; provided that we would only disclose Personal Data on the necessary basis and will notify you of those disclosures.

Your Right as a Data Subject

We respect your statutory rights as the data subject under the relevant laws that include the right to withdraw your consent; right to request for access to Personal Data that are in our possession and request for the copy thereof; right to request for data portability; right to object to any processing of the Personal Data; right to request for the deletion or de-identification if you believe that the Personal Data are collected, used and disclosed illegally; or we do not have any necessity to process your Personal Data; right to request for suspension of the Personal Data processing; right to rectify the Personal Data; and right to complain to any authorities pursuant to the relevant laws of the jurisdiction.

In case you have any inquiries about the Personal Data or you intend to exercise any of your right, please feel free to contact us at:

Name:                    Nauticomm Company Limited

Address:                299/8 Asok Montri Rd. Klongtoey-nua Wattana Bangkok, Thailand 10110

Telephone No.:    +66 2-107-2161


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