PRIVACY POLICY

Last Updated: 2025/2/12
At ZO Motors (Cambodia) Co., Ltd. (“we”, “our”, “us”), we aim to safeguard your privacy to the highest extent possible. Therefore, this Privacy Policy shall outline and govern our policies and procedures on the collection, use and disclosure of your information when you use our website, products, and services (hereinafter collectively referred to as the “Services”). It also explains your rights concerning your personal data and how to exercise them.
Our primary purpose in using your personal information is to deliver and enhance our Services. By accessing the website or using our Services, you consent to the collection, use, and disclosure of your personal information in accordance with the terms and conditions provided hereunder.
Warnings: If you do not agree, please discontinue using our Services.

• ・Account refers to a unique account/profile created by and for you to access whole or in parts of our Services;
• ・Affiliate refers to an entity that controls, is controlled by or is under common control with a party, where “control” means owning 50% or more of the total shares, voting rights, equity interest or other securities entitled to vote for election of directors or other managing authority;
• ・Company refers to ZO Motors (Cambodia) Co., Ltd. duly incorporated under the laws of the Kingdom of Cambodia which may be referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy;
• ・Cookies refer to small text files that are placed on your computer, mobile device, or any other devices by a website to store your browsing data and enhance your surfing experiences;
• ・Country refers to the Kingdom of Cambodia, where the Company is primarily based and operated;
• ・Device refers to any devices that can access the Services, such as computer, mobile phone, digital tablet, or any other smart devices;
• ・Personal Data refers to any and all information relating to an identified or identifiable individual, including but not limited to name, contact details and Internet Protocol address (“IP address”);
• ・Services refers to the website, products, services, and/or other offerings provided by the Company;
• ・Service Provider refers to any natural or legal persons who use and process the data on behalf of the Company within the scope of this Privacy Policy. This definition shall further refer to any third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company such as analytics providers or cloud service platforms;
• ・Usage Data refers to information and data we collected automatically, such as IP addresses, browsing behavior, and interaction with our Services;
• ・Website refers to the official website of the Company, accessible via [http://www.zomotors.co.jp] and all other online platforms of the Company mainly used for providing Services; and
• ・You refers to the individuals accessing or using the Services, or the company, or other legal entities on behalf of which such individual is accessing or using the Services, as applicable, in accordance with its terms and conditions provided herein and other terms established by the Company, which may be referred to as either “you” and “your” in this Privacy Policy.

II. 　　Information We Collect
2.1.　 Personal Data
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information, in this regard, shall include, but is not limited to:

• ・Name: First and last name for identification purposes;
• ・Contact Information: Email address, phone number, and mailing address mainly used for contact and communication with you;
• ・Account Credentials: Username, password, and other login details to create and manage your account;
• ・Payment Details: Billing Information, including credit/debit card details, when you make purchase or top-up for our Services (processed securely through third-party payment processors); and
• ・Usage Data as further elaborated below.

2.2.　 Usage Data
Usage Data is collected automatically when using our Services, including:

• ・Your device’s IP address;
• ・Browser Type, version, and settings;
• ・Browsing history, including the pages you visit on our website and time spent on each page;
• ・Clickstream data, including navigation paths and interactions;
• ・Device type, operating system, unique identifiers, and other diagnostic data; and
• ・Date and time accessed.

We may also collect information that your browser sends whenever you visit our websites or when you access the Service by or through any devices.
2.3.　 Location Data
With your consent, we may collect and process your location data (e.g., GPS data or approximate location based on IP address) to provide location-based Services or improve our offerings or recommendations to suit your needs.
2.4.　 Tracking Technologies and Cookies
We use Cookies, web beacons, and similar tracking technologies to track the activity to collect information and enhance your experience. These may include:

• ・Cookies or Browser Cookies refer to files stored on your device that help us remember your preferences, track your activity, and optimize functionality. You can configure your browser to refuse cookies; however, some features of our Services may be unavailable if cookies are disabled. In our website, we collect both Session and Persistent Cookies. Session Cookies are deleted as soon as you close your web browser, while Persistent Cookies remain on your personal devices despite being offline. We use both Session and Persistent Cookies for the purposes set out below:
  • ・Necessary / Essential Cookies Type: These Cookies, which are Session Cookies, are essential to provide you with Services available through the Website and to enable you to have access and use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you content of those services.
  • ・Cookies Policy / Notice Acceptance and Functionality Cookies Type: These Cookies, which are Persistent Cookies, identify if users have accepted the use of cookies on the Website. These Cookies allow us to remember choices you make when you use our website or Services, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid you having to re-enter your preferences every time you use the website.
• ・Web Beacons refer to small graphic files embedded in emails or website pages to monitor engagement, such as email open rates or page views. Certain sections of our Services and our emails may contain web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who
  have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

In our website, the users remain in full control of how the cookies may be used. For more information about the cookies we use and your choices regarding cookies, please visit the Cookies section of this Privacy Policy.
III.　　How We Handle Your Information
3.1.　 Usage of Your Information
The Company may use and process your Personal Data for various purposes, ensuring the effective delivery, enhancement, and personalization of our Services to tailor your need, including:

• ・Provision and Maintenance of Services: To ensure the proper operation, performance, and monitoring of our Services to equip you with seamless experiences and adapting to evolving user needs;
• ・Account Management and Personalization: Facilitate creation, registration, and management of your account, including updates, and maintaining securities. Your Personal Data enables us to provide personalized content, recommendations, and targeted advertisements based on your preferences, interest, and interaction with our Services;
• ・Contractual Obligation: To fulfill, manage, and comply with contractual obligations bound under the products, items or Services you have engaged or of any other contract with us acquired through our Services and/or platform;
• ・Communication: To enable us to contact you via email, telephone calls, SMS, or other equivalent forms of electronic communication (e.g., mobile app notifications) regarding updates, security alerts, and other information about our Services, products, and/or functionalities, including news, special offers and general information about other products, services and events which we offer that are similar to those that you have already purchased or shown interest in. You may opt not to receive such information or communications at any time in our website settings;
• ・Request Management: To respond to, resolve, or handle any inquires, concerns, or request you have submitted to us;
• ・Fraud Prevention and Security Monitoring: To detect, prevent, and address fraud, unauthorized access, breaches of terms, or any other harmful or illegal activities that could jeopardize the safety of our users or systems;
• ・Legal Compliance and Obligations: To comply with applicable laws, regulations or legal requirements, including responding to lawful request from public and governmental authorities;
• ・Business Transfers: To facilitate or evaluate business transactions, such as mergers, acquisitions, divestitures, restructuring, reorganization, dissolution, or other sales or transfer of some or all of our assets. If Personal Data is part of the transferred assets, it shall remain protected with the same terms and conditions provided herein, unless there is any prior notice to you about the changes of the Privacy Policy which shall require your additional consent; or
• ・Other Purposes: To conduct data analysis, identify usage trends, measure the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing strategies, and your overall experience.

3.2.　　 Sharing of Your Information
We may share your Personal Data with any third parties only under the following persons and circumstances:

• ・With Service Providers: To assist in providing our Services, monitor usage, analyze performance, and facilitate communication;
• ・During Business Transactions: In connection with or during Business Transaction process as aforementioned in the above Clause 3.1. Usage of Your Information, your Personal Data may be transferred to the acquiring or merging entity; however, it remained
  protected under this Privacy Policy, unless there is prior notice to the users about any changes which shall require your additional consent;
• ・With Affiliates: To share your information with our affiliates (including parent companies, subsidiaries, joint venture partners, or any other entities where we have substantial ownership interest) that are required to adhere to this Privacy Policy.
• ・With Business Partners: To collaborate with our business partners in offering you with certain products, services or promotions which tailor to your interest;
• ・With Public and Governmental Authorities: To comply with legal obligations, respond to court orders, or to cooperate with law enforcement or other governmental entities as required by law;
• ・With Other Users: when you voluntarily share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed publicly;
• ・With Your Consent: We may disclose Your personal information for any other purpose explicitly agreed upon by you;
• ・In Encrypted and De-Identified Forms: To share encrypted and anonymized data that cannot be linked back to an individual for research, surveys, marketings, or statistical purposes;
• ・Other Legal Requirements: Your Personal Data may be disclosed in the good faith, believing that such action is necessary to:
  • ・Comply with a legal obligation;
    ・Protect and defend the rights or property of the Company;
    ・Prevent or investigate possible wrongdoing in connection with the Services;
    ・Protect the personal safety of other users of the Services or the public; or
    ・Protect against legal liability.

IV. 　　Retention of Your Personal Data
We will retain your personal data only for as long as is necessary to fulfill the purposes set forth in this Privacy Policy, specifically for:

• ・Compliance with Legal Obligations: we shall retain and use your personal data as required to comply with applicable laws, regulations, and legal processes;
• • Dispute Resolution: Data may be retained to resolve disputes, enforce our rights, and address complaints or issues that may arise;
• ・Enforcement of Contractual Obligations: Your data may be retained to uphold the terms of any agreements or binding documents you have entered into us, including this Privacy Policy and our Terms of Service; and
• ・Business and Operational Purposes: Certain data may be retained temporarily or operational continuity, such as maintaining backups or restoring accounts in the event of accidental deletion.

The Company will also retain Usage Data for internal analysis purposes. When your personal data is no longer needed for the aforementioned purposes, we will securely delete, anonymize, or encrypt such data in accordance with applicable law.
V. 　　Transfer of Your Personal Data
Your information, including Personal Data, may be processed and stored at the Company’s operating offices or at facilities managed by the Service Providers or affiliates located outside your jurisdiction. This may include transfers to countries where data protection laws differ from those in your residence or location.
By consenting to this Privacy Policy, you further consent to the transfer, storage, and processing of your data in countries outside of your jurisdiction.
The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to any organization or a country unless there are adequate security controls in place including the security of your data and other personal information.
VI. 　　Deletion and Updates to Your Personal Data
You have the right to delete whole or in part of your personal data at any times by signing in to Your Account and visiting the account settings section that allows you to manage your personal information or request our assistance in deleting the Personal Data that we have collected about you. However, this right shall be restricted in the event of aforementioned Section
IV. 　　Retention of Your Personal Data
concerning the legal obligations and legitimate interests, where we shall retain your data for compliance and public interest purposes.
VII. 　Security of Your Personal Data
The security of your Personal Data is a top priority for us. We take reasonable precautions and employ commercially measures to safeguard your information from unauthorized access, disclosure, alteration, and destruction by anonymizing and encrypting your data. However, please note that no method of transmitting and storing the data electronically is entirely secure. While we strive to implement robust security measures to protect your personal data and information, we cannot guarantee its absolute security; therefore, we further encourage you to take precautions to protect your information while using our Services. If you believe your Personal Data provided to us has been illegally used or stolen, please contact us immediately for us to appropriate measures.
VIII. 　 Children’s Privacy
Our Services are not intended for any individuals under the age of 13, and within our controls, we do not knowingly collect personally identifiable information from anyone under this age. If you are a parent or guardian and discover that your child has provided us with Personal Data, please contact us immediately. Upon becoming aware of such situation, we will take reasonable steps and measures to remove such information from our servers and systems. In a country where a parental consent is legally required for data processing, we may ask for your parent’s consent before collecting or using your personal data if you are under the legal age of consent.
IX. 　　Links to Other Websites
Our Services may contain links to other external websites or third parties’ services which are not operated or controlled by us. If you click on a link to the third-party website, you will be redirected to that third-party website. In such event, we strongly advise you to review the Privacy Policy of every site you have visited. Please note that we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.
X. 　　Changes to this Privacy Policy
We reserve the right to update our Privacy Policy from time to time. Any changes will be posted on this page and the “Last Updated” version will be displayed on top of this page. If material changes are made, we will notify you via email and/or provide notification on our Services for your additional consent prior to the changes taking effect. We encourage you to review this Privacy Policy periodically for any changes and how your personal data is protected.
XI. 　　Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us via:

• ・Website: http://www.zomotors.co.jp
• ・Email: chargingservice.kh@zo-motors.com
• ・Phone Number:0183573580