#12GO PRIVACY POLICY

12GO PRIVACY POLICY

This 12Go Group General Privacy Policy (hereinafter referred to as the “12GO’s Privacy Policy”) sets out the complete terms and conditions, rights and obligations of 12Go Asia Pte., Ltd., including any and all Affiliates (hereinafter referred to as “12GO” “We”), and You, regarding your booking and purchase of the 12GO’s products and services on the 12GO Internet Sites in accordance with 12GO Group General Terms and Conditions and/or 12GO’s Operator Program Online Tickets Reselling Terms and Conditions and/or 12GO's Affiliate Program Terms and Conditions and/or 12GO's Reseller Partner Program Terms and Conditions and/or any other 12GO's terms and conditions (hereinafter collectively referred to as the “12GO Terms”).

The 12GO’s Privacy Policy incorporates privacy controls and security rules that affect how 12GO will collect, store, and process your personal data and any private information in connection herewith, as well as your rights and obligations towards your personal data.

It is important that you read and understand the 12GO’s Privacy Policy. 12GO collects your personal data and the information you provide to us, such as your or your guest's name, phone number, credit card details, and e-mail address, for contractual obligations or where it is necessary for the purpose of entering into a contract, including notification of the possible effects if you do not provide such personal data. 12GO may also collect passenger name, date of birth, gender, nationality, and passport details (including passport number, country of issue and expiry date) for flight reservations or train reservations. If you do not agree to the following 12GO’s Privacy Policy and its terms or are not authorised to do so, as well as do not intend to book and purchase the 12GO’s products and services within the conditions other than stated hereof, you should discontinue using the 12GO’s Internet Sites.

You hereby grant 12GO a right to use your personal data required to be fulfilled on 12GO’s Internet Sites, to process your payment details, to make all necessary announcements and orders to you, and any and all other requests in connection with your booking and purchase of the 12GO’s products and services and in accordance with the 12GO’s Terms hereof.

DEFINITIONS AND INTERPRETATIONS:

"12GO’s Internet Sites" means any websites that are in possession of 12GO, mainly https://12go.com and https://12go.asia.

"12GO’s products and services" means any type of Services, etc., which are suggested by 12GO for booking and purchase by a Customer at specified prices, clauses, etc. and in accordance with other conditions set by 12GO. The 12GO’s products and services are available on the 12GO's Internet Sites.

"Affiliates" means any entity or person (or collectively entities or persons) who directly or indirectly controls, or is controlled by, or under common control with 12Go Asia Pte., Ltd. For purposes of this definition, "control," "controlling," and "controlled" means having beneficial ownership of more than 50% of the ownership interests of such person or rights to exercise more than 50% of the voting rights of such person, having the right to elect a majority of the board of directors or other comparable body responsible for management and direction of a person by contract, or having the power to direct or cause the direction of the management and policies of such person, whether by virtue of ownership interests or voting securities, by contract or otherwise.

"Business Day'' means any day (other than Saturday or Sunday or holidays) on which banks are open for general business in 12GO’slegal domiciles.

“Carriers” means any legal entity or person (or collectively legal entities or persons) who provides and renders relevant types of Services to customers pursuant to a contract of provisions of services concluded between him and them (in the form of tickets or any other) and in accordance with all established procedures, applicable laws and legal requirements, enactments, orders, security guidelines, rules and regulations and other similar legal instruments.

"Customers" means any person or entity who is willing to book and purchase the 12GO’s products and services on the 12GO’s Internet Sites and under the 12GO’s Terms.

"Personal data" means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier of that natural person (including but not limited to a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity, etc.). In connection thereto, the definitions of “personal data” may vary depending on the regulations applicable in each state.

"Services" means any type of an activity, entertainment services relevant to recreation and leisure, including vehicle (or any other mode of transport) rental services; and/or hotel services, services of Customers accommodation (including Customer’s baggage and belongings) in a specific type of lodging (buildings, apartments, dorms, villas, flats, rooms, etc. or any other); and/or transport services, services of Customers transportation (including Customer’s baggage and belongings) to a particular destination; and/or visa support services, services of Customers visas providing or assistance in applying for visa(s) (including but not limited to personal documents collection, embassy appointment , other relevant visa support), and/or insurance services (any available insurance instruments (variable from region to region) which may be presented as contracts to protect Customer's life, health, Customer’s baggage and belongings and any other property during their trip based on purchased tickets, against any possible loss and or damage, including a reimbursement of health care costs, repayments of death benefits to designated beneficiaries for life insurance policyholders and any other relevant and designated reimbursement), provided and rendered by a Supplier and/or Carrier in accordance with booked and purchased tickets and/or insurance vouchers.

“Suppliers” means any legal entity or person (or collectively legal entities or persons) who acts on behalf of any Carrier pursuant to agreements or commercial relationships between them and, in accordance herewith, provides Customers with information related to the relevant types of Services of such Carrier. All information, type of Services, etc., belong to and are controlled by a certain Supplier and/or Carrier.

“Trusted” in connection to Carriers, Suppliers, 12GO’s third-party partners, their websites or any other websites or any other electronic tools which, in 12GO’s opinion, are recognised as trusted ones, shall mean a person or entity (or collectively persons or entities) who either is recognised by 12GO as its business partner or with whom 12GO has a legal contractual relationship or is a globally trusted and recognised service provider or any similar to such one.

ELIGIBILITY. SUBJECT MATTER:

You hereby acknowledge and guarantee the full entitlement and authority to enter into the 12GO’s Terms and the 12GO’s Privacy Policy any other documents executed by 12GO that may be associated with the 12GO’s Terms and the 12GO’s Privacy Policy; such a right shall be expressed by direct consent with the 12GO’s Terms within your booking and purchase of 12GO’s product and services on the 12GO’s Internet Sites (by means of clicking the checkbox "I accept Terms and Conditions and Privacy Policy" placed in the booking and payment window on the 12GO's Internet Sites).

12GO is committed to protecting your personal data and takes responsibility for securing any and all customer personal data and private information in connection with the use of this website or any other entity in control of 12GO.

The 12GO’s Privacy Policy sets out how 12GO uses and protects the personal data you provide hereafter and/or while using the 12GO’s Internet Sites.

This 12GO’s Privacy Policy shall also be applied where 12GO is acting as a “data controller” or a “data processor” with respect to the personal data of the website visitors and service users and in accordance with the regulations which are applicable in each state and subject to governmental amendments from time to time.

12GO is entitled at any time to amend or modify the 12GO’s Terms without prior notification to you. The latest version of the 12GO’s Privacy Policy is always available on the 12GO’s Internet Sites, and you hereby represent that you shall be acquainted with the latest version of the 12GO’s Privacy Policy on your own.

The 12GO Privacy Policy does not apply to general practices and treatment of information (whether personal or not) by third parties that 12GO does not own or control, including but not limited to any third-party websites or services that you select to access through the 12GO’s Internet Sites.

By entering into the 12GO’s Privacy Policy, you acknowledge and understand that if you choose to book and purchase any of the 12GO’s products and services offered on the 12GO’s Internet Sites by certain Carriers and/or Suppliers and/or by any third party partner (collectively referred to the “third-party partners''), you may be a customer of and subject to the legal requirements, terms and conditions of either both or of 12GO or of the third party partners. In this regard, 12GO and the third-party partners may collect and share with each other your personal data and private information (including but not limited to your booking and purchase, your personal details, your billing information, etc). 12GO is not responsible for the third-party partners’ actions in connection to the collection, use and sharing of your personal data where either such actions are not under the control of 12GO or 12GO is not directly involved in such actions and does not request your permission to do so. In such cases, you should consult the privacy policies of the third-party partners.

By entering into the 12GO’s Privacy Policy, you ensure your clear and full consent to provide your personally identifiable data and to use this website in accordance with the conditions set herein; you also ensure that you are older than 16 years; otherwise, your parents or legal guardians should give such consent.

PERSONAL DATA COLLECTION:

12GO may collect your personal data when you make bookings and purchases of the 12GO’s products and services on the 12GO’s Internet Sites (including but not limited to either directly or indirectly through the 12GO’s trusted Carriers, Suppliers and/or the third parties partners), create your personal account on the 12GO’s Internet Sites, use on the 12GO’s Internet Sites and/or mobile (or any other) application in connection thereto and other websites accessible through the 12GO’s Internet Sites and/or mobile (or any other) application, participate in a survey or competition, or when you contact 12GO.

12GO may also collect the following personal data:

■ your profile and contact data (including your name and surname, passport (ID) details or other recognised personal ID card numbers and details, date of birth, gender, address, telephone numbers, email addresses, details of your travels, other travel information on bookings made at this website, information of other passengers travelling with you (name, surname, passport (ID) details or other recognised personal ID card numbers and details, date of birth, gender, other travel information, etc.));
■ your payment data (including your bank details or payment cardholder details, payments gateways account or other bank, e-payment or financial institution account information);
■ other information in connection with your booking and purchase of the 12GO’s products and services, which may be requested by specific Suppliers and/or Carriers;
■ other payment information, which may be required by governmental, tax, audit, or bank authorities to complete or check your booking and purchase of the 12GO’s products and services and corresponding payment transactions;
■ your usage data (your locations, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the location services settings on your device or computer; browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, etc.);
■ your correspondence data (information contained in or relating to any communication that you send to 12GO, including file attachments you may provide);
■ your enquiry data (information contained in any enquiry you submit to us regarding goods and/or services 12GO provided);
■ other information relevant to customer surveys and/or offers is a review you leave about certain suppliers and/or carriers after your travel.

Certain types of personal data, such as religion or health-related information, are considered sensitive and may require additional protection under applicable laws. Although 12GO does not ordinarily collect sensitive personal data as part of bookings, there may be a need to, from time to time, collect such information, e.g. as contained in a government-issued identification document or medical certificate if such information is supportive of a transaction or request that you ask 12GO to perform on your behalf such as cancellation or amendment of your booking, or if you may choose to share such information voluntarily through any contact you may have with 12GO. You may also elect to provide 12GO with other information that may imply or suggest information like religion, health, or other information, such as when specifying your dietary needs. The collection and processing of such sensitive personal data will be in line with what is set out in this privacy statement.

PERSONAL DATA COLLECTION PURPOSES:

12GO collects, uses, and/or discloses your personal data on the legal basis of (1) a contractual basis for starting or entering into a contract or for the performance of a contract with you; (2) a legal obligation, to fulfil our legal obligations; (3) legitimate interest, for our legitimate interests and those of third parties; (4) vital interest, for the prevention or suppression of danger to a person’s life, body, or health. We do this to understand your needs and provide you with better Services, including :

■ providing you with access to the 12GO’s products and services you requested on the 12GO’s Internet Sites. Personal data you provide to 12GO is used for the purpose of the services provision that you have requested, including requests for any waivers, changes, modifications, cancellations, etc. 12GO sends only the required data to the certain Suppliers and/or Carriers who are directly involved in your bookings and purchase of the 12GO’s products and services, including your reviews and feedback to allow certain Suppliers and/or Carriers to improve their services.
■ Providing you with any information in the event of any waiver, change, modification or cancellation of the 12GO’s products and services booked and purchased by you, including notifications on weather conditions, travel delays, force majeure, etc.
■ Accounting, billing, and audit purposes are used to detect and/or prevent any fraudulent or money laundering activities. 12GO may share your payment data with third-party partners (a payment operator, bank or financial institution, credit and debit card companies, the method of which you selected for your payment for 12GO’s products and services, and maybe (but not obligatory) available on the 12GO’s Internet Sites).
■ Providing and improving the 12GO’s products and services for the purposes of operating and analysing the use of the 12GO’s Internet Sites, for their monitoring and improving, for ensuring the security of the 12GO’s Internet Sites, the 12GO’s products and services, maintaining back-ups of our databases and communicating with you.

Failure to provide personal data to us may result in 12GO being unable to respond to your request to perform contractual obligations or fulfil our legal obligations. As a result, 12GO may not be able to offer or provide you with the 12GO’s products and services, whether partially or entirely.

As elaborated in the 12GO Group General Terms and Conditions, we reserve the right to utilise algorithmic tools and employ machine learning techniques to enhance and refine our services. These tools encompass a spectrum of functions, such as predictive analytics and generative AI algorithms for content creation. Your information may be utilised by these tools in specific instances where such tools are deployed. We ensure that our deployment and utilisation of these tools adhere to applicable laws and regulations, as well as other pertinent considerations, to maintain ethical and compliant practices.

PERSONAL DATA SHARING:

Your personal data collected by 12GO may be shared with the 12GO’s Affiliates and other companies within the 12Go Group.

12GO operates its businesses worldwide in multiple jurisdictions, some of which are not located in the European Economic Area (EEA), including but not limited to the Member States of the Western Europe, Central and Eastern Europe, Asia, Africa, Mediterranean & Middle East. The list of the trusted Carriers, Suppliers and the third party partners are available on the 12GO’s Internet Sites.
While countries outside the EEA do not always have data protection laws, 12GO requires all the trusted Carriers, Suppliers, and third-party partners to collect, store and process your personal data in a secure manner and in accordance with the laws and regulations which are applicable in each state.

If your personal data is subject to the General Data Protection Regulation (EU) 2016/679 (GDPR) protection, please be aware that while 12GO collects and transfers your personal data outside the EEA, 12GO always complies with the GDPR provisions in order to ensure the level of protection of personal rights available inside the EEA. In case of transferring your personal data outside the EEA, it will be protected by the appropriate safeguards or binding corporate rules, a copy of which you can obtain either from the 12GO’s Internet Sites or trusted websites of the trusted Carriers, Suppliers and third-party partners presented on the 12GO’s Internet Sites.

12GO may also share your personal data with the following third parties for the purposes described hereof:

■ government authorities, law enforcement bodies, regulators and airports in your itinerary and for compliance with all applicable laws, regulations and other similar legal instruments;
■ audit organisations (auditors) for carrying out an audit upon their request and only in cases when it is required for the conduction of such an audit;
■ public agencies, state authority and persons authorised to request such information in accordance with the applicable laws, on the basis of a formal request for providing such information or in order to provide a state public accountability;
■ trusted Global Distribution System (GDS) agents and/or the third-party partners;
■ trusted Carriers and/or Suppliers required to deliver the performance of the 12GO’s products and services you have requested on the 12GO’s Internet Sites;
■ trusted service providers 12GO uses to run its business in those countries where 12GO operates, call centres providing assistance to Customers, cloud service and email marketing service providers assisting the 12GO’s marketing team with running customer surveys and providing targeted marketing campaigns;
■ a payment operator, bank or financial institution, credit and debit card companies, the method of which you selected for your payment for the 12GO’s products and services, which facilitate your payments, and anti-fraud screening, which may need information about your methods and processes of payment to ensure the security of your payment transactions;
■ legal and other professional advisers, public agencies, law courts and law enforcement bodies in all countries where 12GO operates in order to enforce all required legal rights in relation hereto.

In certain circumstances, 12GO may disclose your personal data to third parties if 12GO determine that such disclosure is necessary and in the following cases:

■ to protect and to assert your and 12GO’s legal rights and the legal rights of third parties in connection hereto;
■ to protect 12GO’s systems, assets, employees, members and customers;
■ to ensure the integrity and operation of 12GO’s business and systems;
■ to protect 12GO’s business against multiple risks;
■ to obtain or to maintain insurance coverage, managing risks, or to obtain professional advice;
■ to comply with legitimate and enforceable governmental requests, subpoenas or court orders, where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

12GO may choose to comply with or disregard such requests or orders in its sole discretion.

PERSONAL DATA STORING AND SECURITY:

All your personal data is collected, processed, and kept for internal record keeping as required by the applicable laws and regulations. 12GO only processes your personal data where it is necessary to do so. The legal basis will depend on the reasons 12GO has to collect and use your personal data.

Personal data that 12GO processes for any purpose shall not be retained for longer than it is necessary for those purposes and under the applicable laws and regulations. Where it is impossible to specify in advance the periods for which your personal data will be retained, 12GO will determine the period of retention based on the purposes of collecting your personal data and the exhaustion of the need to retain it. For the purposes of determining the appropriate retention period, 12GO considers the amount, nature and sensitivity of the personal data and the purposes for which the personal data is collected and processed. For example, the expected data retention period is ten (10) years from the date at which the services were terminated.

When 12GO no longer needs personal data, it will be securely deleted or destroyed. 12GO will also consider if and how 12GO can minimise over time personal data processed by 12GO and if it can be anonymised so that it can no longer be associated with you or identify you, in which case 12GO may use that information without further notice to you.
Notwithstanding the other provisions herein, 12GO may retain your personal data where such retention is necessary for compliance with any legal obligation to which 12GO is subject or in order to protect your vital interests or the vital interests of another natural person or persons.

12GO is committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, 12GO has put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information collected online.

In case 12GO discloses your personal data to the trusted Carriers, Suppliers and/or third-party partners for the purposes set out in the 12GO’s Privacy Policy, 12GO always requires them to have the appropriate technical and operational security measures in place to protect your personal data.

12GO will not sell, distribute or lease your personal data to any third parties unless 12GO has your permission or it is required by the applicable laws and regulations. 12GO may use your personal data to send you promotional information about the Carriers, Suppliers and/or other third parties, which, in 12GO’s opinion, you may find interesting; however, subject to your prior consent and or its further withdrawal.

YOUR PERSONAL DATA RIGHTS:

Your principal rights towards your personal data provided to 12GO under the 12GO’s Privacy Policy are:

■ the right to access;
■ the right to rectification;
■ the right to erasure;
■ the right to restrict processing;
■ the right to object to processing;
■ the right to data portability;
■ the right to complain to a supervisory authority, and
■ the right to withdraw consent.

You are also entitled to:

■ request the details of your personal data which 12GO holds about you;
■ restrict the collection or use of your personal data by indicating that you do not want your personal data to be used for direct marketing or promotional purposes which do not directly concern your travel data or data necessary for your booking and purchase of the 12GO’s products and services;
■ to withdraw your consent and delete your personal data at any time by clicking the “delete” buttons provided in your personal profile on the 12GO’s Internet Sites.

The disposal of your personal data is possible only after completing all your booked and purchased 12GO's products and services. If you wish to delete your personal data before completion, 12GO will have to cancel your bookings and purchases. It will be unable to inform you about any unexpected changes, cancellations or other influences on your future travels and/or booked and purchased 12GO’s products and services.

You should be aware that some of your personal data can not be disposed of or deleted for the purpose of complying with the applicable laws and regulations to which 12GO is a subject and/or in order to protect your vital interests or the vital interests of another natural person or persons and/or for accounting, billing and audit purposes and/or to detect and/or prevent any fraudulent or money laundering activities.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, 12GO may charge a reasonable fee if your request for access is clearly unfounded or excessive. Additionally, 12GO may refuse to comply with the request in such circumstances.

You should be aware that 12GO may request specific information from you, which may help 12GO confirm your identity and ensure your right to access the information and personal data or exercise any of the other rights. It is a necessary and appropriate security measure to ensure that your personal data is not disclosed to any person with no entitlement for this.

12GO also understands the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, children under 16 years of age will not be permitted to open any account with 12GO. 12GO will delete any such accounts if 12GO is made aware that it was created by a child under 16 (subject to the 12GO Group General Terms and Conditions). Where required by applicable law, 12GO may ask for certain information about children from parents or guardians to process a booking or provide other services. If you are a parent and believe we may have inadvertently collected personal data from a minor, please notify us, and we will remove that personal data and unsubscribe that minor from any of our electronic marketing lists. Minors can normally accompany their parent(s) or legal custodian(s) who have booked our services unless prohibited by suppliers' policies.

COOKIES:

“Cookie” or collectively “Cookies” means a file (or collectively files) containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. A cookie is a small file which requests permission to be placed on your computer's hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site.

12GO uses traffic log cookies to identify which pages are being used. This helps to analyse data about web page traffic and improve the 12GO’s Internet Sites to monitor which pages you find useful and which you do not. A cookie in no way gives 12GO access to your computer or any information about you other than the data you choose to share with 12GO.

12GO uses cookies for the following purposes:

■ authentication - to identify you when you visit or navigate the 12GO’s Internet Sites;
■ status - to help 12GO to determine if you are logged into the 12GO’s Internet Sites;
■ personalisation - to store information about your preferences and to personalise the 12GO’s Internet Sites for you;
■ security - to protect users’ and Customers’ accounts, including preventing fraudulent use of login credentials, and to protect the 12GO’s Internet Sites and the 12GO’s products and services generally;
■ advertising - to help 12GO to display advertisements that will be relevant to you;
■ analysis - to help 12GO to analyse the use and performance of the 12GO’s Internet Sites and the 12GO’s products and services;
■ cookie consent - to store your preferences in relation to the use of cookies more generally.

12GO also uses cookies from trusted service providers, including but not limited to Google, Bing, Yahoo, Yandex, Twitter, and Facebook. The information gathered relating to the 12GO’s Internet Sites is used to create reports about their use. 12GO is not responsible for third parties' use of your personal data where such use is permitted for their own purposes. Please consult their privacy policies for further information.

You can choose to accept, decline or block cookies. You can modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of any website. Blocking all cookies will have a negative impact on the usability of many websites.

INTERNATIONAL DATA TRANSFERS:

The data collected for the purposes outlined above may be retained in locations beyond your native country, where data protection standards may differ from those in your home jurisdiction. We shall enact suitable safeguards for any cross-border data transfers, as mandated by the relevant laws and regulations, including for data transmitted to authorised third parties, including but not limited to 12GO’s subsidiaries, holding companies, members of the group, affiliates, assigns, assignees, successors, trusted agents and third-parties tools. Additionally, if necessary, we may obtain your consent for such cross-border data transfers.

LINKS TO OTHER WEBSITES:

The 12GO’s Internet Sites may contain links to other websites of interest.

The links under 12GO’s control are https://12go.com/en https://12go.asia/en https://agent.12go.com/ https://reseller.12go.com/ https://op.12go.asia/

Other links contained on the 12GO’s Internet Sites are not under 12GO’s control. However, once you have used such links to leave 12GO’s Internet Sites, you should note that 12GO does not have any control over those other websites. Therefore, 12GO cannot be responsible for the protection and privacy of any information you provide whilst visiting such websites and such websites are not governed by the 12GO’s Privacy Policy. You should exercise caution and look at the applicable privacy statement.

SUPPLEMENTARY PROVISIONS:

12GO’s Internet Sites are not intended for use by individuals under the age of 18 years. In jurisdictions where mandated by applicable laws and regulations, 12GO may solicit certain information pertaining to minors from their parents or legal guardians in order to facilitate travel bookings or render other services. If you are a parent or guardian and believe that 12GO has inadvertently collected personal data from a minor, please promptly notify us, and we will expunge such personal data from our systems and remove the minor from any electronic marketing lists maintained by 12GO.
Unless expressly prohibited by the policies of the relevant travel suppliers, minors are generally permitted to accompany their parent(s) or legally appointed custodian(s) who have made a valid travel booking through 12GO’s Internet Sites.

MISCELLANEOUS:

12GO reserves the right to update its Privacy Policy periodically by publishing a revised version with the effective date noted on the 12GO’s Internet Sites. We encourage you to check this page occasionally to ensure your agreement with any modifications. 12GO may notify you of significant changes to the 12GO’s Privacy Policy before implementation and seek your consent if required by law.

You can contact 12GO by post to 12GO’s operating office in Thailand, No. 318, 3rd Floor, DOB Building, Room No. C 3, Rama IV Road, Maha Phruttharam Sub-district, Bang Rak District, Bangkok Metropolis, 10500, or by using the Support Contact Form.

If you believe that any information 12GO is holding on you is incorrect or incomplete, please write to support@12go.asia or use the Support Contact Form as soon as possible. 12GO will promptly correct any information found to be incorrect.

All other provisions, rights and obligations, and terms that are not covered by the 12GO’s Privacy Policy shall be interpreted in accordance with the 12GO Terms and the applicable laws and regulations regarding personal data protection.