Privacy Policy

This Privacy Policy explains how Lao Smart Mobility Co., Ltd (individually and collectively referred to herein as “Company”, “us", " we" or " our") collects, uses, discloses, processes the Personal Data collected by the use of our application(including the KOKKOK Move, KOKKOK Hero), websites, services(hereinafter referred to as, “App”).

Please read this Privacy Policy and understand it before using our service. By using the service, an individual who wants to become a Hero/customer(collectively “you”, “your” or “yours”) agrees and, where required, consent to the collection, use and transfer of your information as set out in this policy.

  1. I. COLLECTION OF PERSONAL DATA

    “Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, date of birth, vehicle and insurance information, employment information and financial information.

    We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:

    1. it is required for us to comply with legal requirements;

    2. it is required for us to enter into or perform a contract with you; and/or

    3. for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Policy.

    We collect(and may combine) Personal Data about you in the ways listed below:

    1. 1. You provide your Personal Data to us

      1. We collect your Personal Data when you provide it to us. For example, when you:

        1. complete a user profile or registration forms (such as your name, contact information and other identification information where needed);

        2. provide information to assess your eligibility to provide ride hailing or delivery service as a service provider/employee (such as your driver’s license information, vehicle information and background check results);

        3. verify your identity through various means (such as submission of selfie images or independently verified payment card information);

    2. 2. When our Services are used

      1. Personal Data may be collected through the normal operation or use of our Apps, Websites and Services. Some examples are:

        1. your location information;

        2. transaction information (such as payment method);

        3. information about how you interacted with our Apps, Website or Services (such as features used and content viewed);

        4. device information (such as hardware model and IP addresses), file and app names(service names) and app versions, GPS location, and advertising identifiers or any information that may indicate device or app modification);

    3. 3. From other sources

      1. When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

        1. referral programmes;

        2. our business partners, such as payment providers, service provider or employees;

        3. insurance and financial providers;

        4. credit bureaus, alternative credit scoring agencies and any other credit reporting organizations;

        5. publicly available or governmental sources of data;

        6. when our users add you as an emergency contact;

        7. when you add other individuals as a recipient or beneficiary of any use of our app;

        8. marketing services providers or partners.

    4. 4. Sensitive Personal Data

      1. Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your national ID information, background information (including financial and criminal records, where legally permissible), disability, as applicable. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required for that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.

    5. 5. When you provide Personal Data of other individuals to us

      1. In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you add them as recipients or beneficiaries of any use of our app. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Policy.

    6. 6. Personal Data of minors

      1. As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to our app. In the event that such Personal Data of a minor is disclosed to our app, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by Privacy Policy and take responsibility for their actions.

  2. II. USE OF PERSONAL DATA

    We may use your Personal Data for the following purposes set out in the list below. (“Purposes”). Additionally, if you use our app in various capacities (for example, if you use multiple KOKKOK Move services, or if you are both a customer and service provider/employees), we may link your Personal Data collected across your various capacities to facilitate your use and for the Purposes described below:

    1. 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 to provide you with 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, 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 Apps experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalize your experience with KOKKOK Express);

        8. perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, 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. 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 Move or KOKKOK Hero;

        3. using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;

        4. sharing consumer of service provider/employee’s location and details When the service provider/employees accepts the customer's request and then pick up the goods or customer; and

        5. monitoring compliance with our terms of service and policies.

    3. 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 our user support responses;

        3. respond to questions, comments and feedback; and

        4. inform you about steps taken to resolve customers’ support issues.

    4. 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 analyse 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 development of insurance and finance solutions.

    5. 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; and

        3. protect our rights or property in the event of a claim or dispute.

    6. 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 our partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

        1. send you special offers that may be of interest or relevance to you across all of KOKKOK Move’s service offerings;

        2. send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and

        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 by email).

      3. If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our Apps 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 need to share Personal Data with various parties for the Purposes. These parties include:

    1. 1. Other users

      1. For example:

        1. If you are a customer, we may share your username, pick-up and drop-off locations with a service provider/employee fulfilling your request;

        2. If you are a service provider/employee, we may share your Personal Data with a customer/recipient including your name and photo; your vehicle make, model, number plate, location;

        3. If you are a customer, we may share your Personal Data with the recipient of your parcel, and vice versa, as well as the service provider/employee in charge of fulfilling your request;

    2. 2. With third parties

      1. With third parties related to your use of our app.

      2. For example :

        1. If you are a service provider/employee, we may share a vehicle’s location and a service provider’s/employee’s name with third parties when a service provider/employee is dispatched.

        2. If you are a service provider/employee, we may disclose your vehicle plate number or other personal data to the insurance company for the purpose of submission of insurance claims.

    3. 3. With KOKKOK Express' service providers and business partners

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

        1. payment processors and facilitators;

        2. debt collectors;

        3. credit bureaus, alternative credit scoring agencies and any 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;

    4. 4. 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 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; or

        2. where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

    5. 5. Business transfers

      1. 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 allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data 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.

  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 allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data 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. 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, which 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. Cookies may be used for various purposes such as to:

        1. provide the essential, basic functions of the use of our app;

        2. authenticate you, or remember your user preferences and settings;

        3. delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;

        4. analyze site traffic and trends

        5. serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and

        6. enhance 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 the Websites and Apps to collect the same type of Personal Data for the same purposes we does for itself. 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. 2. Disabling the collection of cookies on our websites

      1. You have the right to choose to disable, block or deactivate cookies. Please note that however refusal or removal of some cookies could affect the availability, functionality or use 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” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information.

    3. 3. Disabling the display of Targeted Ads through our App

      1. We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of.

      2. You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers, by adjusting your preference through the Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA or Google’s GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the use of such mobile identifiers.

      3. Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.

  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 used or accessed in an unauthorized way. 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; and

    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.

  8. VIII. AMENDMENTS AND UPDATES

    We may modify, update or amend the terms in this Privacy Policy at any time. Such amendments shall 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 the website https://laosmartmobility.com. It is your responsibility to review the Privacy Policy regularly. 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, shall constitute your agreement to be bound by such amendments.

  9. 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 mail 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 the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.

    The latest update date: 25 October, 2023