គោលការណ៍ឯកជនភាព

1. Introduction and Legal Basis

OonePower Technology Co., Ltd. (“OonePower,” “we,” “us,” or “our”), a corporation duly incorporated and registered under the laws of the Kingdom of Cambodia, is committed to safeguarding the privacy and security of your personal data in accordance with applicable legal frameworks. This Privacy Policy (“Policy”) governs the collection, use, storage, disclosure, and processing of personal data through the UnifyCharge Mobile Application (“App”), an integral component of the UnifyCharge EV Charging Ecosystem. The App facilitates Users (“you,” “your,” or “User”) in locating, reserving, and effecting payment for electric vehicle (“EV”) charging sessions at charging stations throughout Cambodia, integrated with the national charging network and administered via the UnifyCharge Centralized Charge Point Management System (“CSMS”).

This Policy is formulated to ensure compliance with the Kingdom of Cambodia’s legal statutes, including but not limited to the Law on Electronic Commerce (LEC) and the Consumer Protection Law (CPL), as well as any applicable data protection guidelines promulgated by competent authorities, notwithstanding their evolving nature. By accessing, downloading, or utilizing the App, you expressly acknowledge that you have reviewed, comprehended, and consented to the data practices delineated herein. Should you withhold such consent, you are precluded from accessing or using the App.

2. Definitions

For the purposes of this Policy, the following terms shall bear the meanings ascribed below, unless the context otherwise requires:

Personal Data

Any information relating to an identified or identifiable natural person, encompassing, without limitation, name, email address, telephone number, payment particulars, and geolocation data.

Processing

Any operation or set of operations performed upon Personal Data, whether by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, or erasure.

Data Controller

OonePower, being the legal entity that determines the purposes and means of Processing Personal Data pursuant to this Policy.

Data Processor

Any natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller, including third-party service providers such as payment processors or cloud hosting entities.

3. Data Collection

We collect Personal Data to enable the provision, maintenance, and enhancement of the App’s services. The categories of Personal Data collected include:

Account Information

Full name, email address, telephone number, and ancillary details submitted during the account registration process.

Payment Information

Financial particulars, such as bank account details and transaction histories, amassed when effecting payments via direct bank transfer or KHQR, or when augmenting the Digital Wallet.

Location Data

Geospatial coordinates derived from your device to facilitate location-specific functionalities, such as identifying proximate charging stations.

Usage Data

Metrics and analytics concerning your interaction with the App, including accessed features, executed actions, and session durations.

Device Information

Technical specifications, including Internet Protocol (IP) address, operating system, unique device identifiers, and network connectivity data, to ensure operational compatibility and security.

Support Data

Correspondence and information furnished during interactions with our support services, including emails, messages, or support tickets.

Such Personal Data is amassed via:

• Direct submission by the User (e.g., during registration or payment transactions).
• Automated technologies (e.g., device sensors capturing location data).
• Third-party integrations (e.g., payment processing entities).

4. Data Use

We undertake the Processing of your Personal Data for the following lawful purposes, predicated upon your express consent and the necessity to perform contractual obligations:

Service Provision

To administer your account, process financial transactions, facilitate charging session reservations, and deliver the App’s core functionalities.

Service Enhancement

To analyze usage trends, develop novel features, and optimize the App’s performance and User experience.

Communication

To disseminate service-related notifications, updates, and, where permissible under law, promotional materials.

Security and Fraud Mitigation

To detect, prevent, and remediate unauthorized access, fraudulent activities, or other security threats.

Legal Compliance

To fulfill statutory obligations, regulatory mandates, or lawful directives from competent authorities.

Your consent, as manifested by acceptance of this Policy, constitutes the legal basis for Processing. You retain the right to withdraw consent at any juncture by contacting us, albeit such withdrawal may impair your ability to utilize certain App functionalities.

5. Data Sharing

We may disclose your Personal Data to the following recipients, strictly for the purposes articulated herein and subject to contractual safeguards:

Service Providers

Third-party entities engaged to support App operations, including payment processors, cloud hosting providers, and customer support facilitators, each bound by confidentiality and data protection obligations.

Charge Point Operators (CPOs)

Independent proprietors or operators of charging stations, to enable the reservation and execution of charging sessions.

Government Authorities

As mandated by law or in response to lawful requests, such as for regulatory compliance, public safety, or judicial proceedings.

Business Partners

Entities with whom we collaborate to deliver integrated services, subject to stringent confidentiality agreements.

We unequivocally prohibit the sale, lease, or unauthorized disclosure of your Personal Data to third parties for marketing purposes absent your explicit, affirmative consent.

6. Payment Data

When effecting payments or augmenting your Digital Wallet via the App:

Processing

Payment particulars associated with direct bank transfers and KHQR transactions are collected and securely transmitted to third-party payment processors and banking partners for transaction execution.

Storage

Transaction records are retained in a secure manner to facilitate billing, auditing, and compliance with legal obligations.

Security

Payment data is encrypted and processed in conformity with prevailing industry standards.

Third-party payment processors and banking partners bear independent responsibility for safeguarding your payment information, governed by their respective privacy policies and legal duties.

7. Data Protection

We deploy robust technical and organizational measures to protect your Personal Data against unauthorized access, loss, misuse, or alteration, including:

Encryption

Utilization of industry-standard cryptographic protocols to secure data during transmission and at rest.

Access Controls

Implementation of role-based access restrictions, adhering to the principle of least privilege, to limit data access to authorized personnel only.

Security Audits

Periodic evaluations to identify and rectify vulnerabilities within our systems.

Incident Response

Established protocols to detect, report, and address data breaches in compliance with applicable legal mandates.

Notwithstanding these measures, absolute security cannot be guaranteed. You bear responsibility for maintaining the confidentiality of your account credentials and are obliged to promptly report any suspected unauthorized access to support@unifycharge.com.kh.

8. User Rights

Subject to the laws of the Kingdom of Cambodia and prevailing data protection guidelines, you are vested with the following rights concerning your Personal Data:

Right of Access

To request and obtain a copy of the Personal Data we hold pertaining to you.

Right to Rectification

To demand correction of inaccurate or incomplete Personal Data.

Right to Erasure

To request deletion of your Personal Data, subject to statutory retention obligations.

Right to Restriction of Processing

To seek limitation of Processing under specified circumstances, such as pending resolution of a dispute.

Right to Object

To oppose Processing for designated purposes, including direct marketing.

Right to Data Portability

To procure your Personal Data in a structured, commonly used, and machine-readable format.

To exercise these rights, submit a written request to support@unifycharge.com.kh. We shall endeavor to respond within thirty (30) calendar days, consistent with legal requirements.

9. Data Retention

We retain your Personal Data solely for the duration necessary to:

• Fulfill the purposes for which it was collected, including provision of the App’s services.
• Comply with statutory obligations, such as record-keeping mandates under Cambodian law.
• Resolve disputes or enforce contractual agreements.

Upon lapse of the requisite retention period, your Personal Data shall be securely deleted or anonymized, save where retention is compelled by law.

10. Children’s Privacy

The App is not designed or intended for use by individuals under the age of 18. We do not knowingly collect Personal Data from children under 13 absent verifiable parental consent. Should we ascertain such data has been collected, we shall undertake reasonable efforts to expunge it forthwith.

11. International Transfers

Your Personal Data may be transferred to, and processed in, jurisdictions beyond the Kingdom of Cambodia, such as for cloud storage or third-party service provision. We warrant that such transfers shall conform to applicable Cambodian laws and be accompanied by adequate safeguards, including standard contractual clauses or reliance upon adequacy determinations, to ensure the continued protection of your data.

12. Updates to This Policy

We reserve the right to amend this Policy to reflect modifications in our data practices, legal obligations, or App functionalities. Material amendments shall be communicated via email or in-App notifications, affording a minimum of seven (7) calendar days’ notice prior to their effective date. Your continued use of the App subsequent to such updates signifies acceptance of the revised Policy. We urge periodic review of this Policy.

13. Contact Information

For inquiries, grievances, or to exercise your data rights, contact our designated Data Protection Officer at:

14. Miscellaneous

14.1 Governing Law and Jurisdiction

This Policy shall be governed by, and construed in accordance with, the laws of the Kingdom of Cambodia. Any disputes arising hereunder shall be resolved pursuant to the dispute resolution mechanisms stipulated in the App’s Terms and Conditions, with exclusive jurisdiction vested in the courts of Cambodia.

14.2 Language

This Policy is executed in English and Khmer. In the event of any inconsistency, the English version shall prevail to the fullest extent permitted by law.

14.3 Entire Agreement

This Policy, in conjunction with the App’s Terms and Conditions, constitutes the entire agreement between you and OonePower concerning the Processing of your Personal Data, superseding all prior representations, understandings, or agreements.

14.4 Severability

Should any provision of this Policy be adjudged invalid, illegal, or unenforceable by a competent authority, such determination shall not impair the validity or enforceability of the remaining provisions, which shall remain in full force and effect.

14.5 Force Majeure

OonePower shall not be liable for any failure or delay in performing its obligations under this Policy arising from events beyond its reasonable control, including acts of God, war, governmental actions, or natural disasters.

14.6 Waiver

No failure or delay by OonePower in exercising any right or remedy under this Policy shall constitute a waiver thereof, nor shall any single or partial exercise preclude further exercise of such rights or remedies.