Privacy Policy
Last Updated: 20 February 2025 | Effective Date: 20 February 2025
1. Introduction
Samruay ("we", "us", "our") is committed to protecting the personal information of all individuals who interact with our services. This Privacy Policy describes what data we collect, how we use it, and the rights you have in relation to it. It applies to all users of our website and participants in our courses.
If you have questions about this Policy, please contact us at [email protected].
2. Data We Collect
We may collect the following categories of personal information:
- Name and contact details (email address, phone number) submitted via our website contact form
- Course enrolment information including the course(s) selected and payment confirmation
- Information shared voluntarily during advisory sessions, including health and financial context relevant to the course
- Technical data collected automatically (IP address, browser type, pages visited, cookie identifiers)
We do not collect sensitive personal data (such as health records or financial account details) unless you choose to share it during a course or advisory session, and only with your explicit consent.
3. Legal Basis for Processing
We process your personal data under the following lawful bases as defined by Thailand's Personal Data Protection Act (PDPA) B.E. 2562:
- Consent: For marketing communications and optional cookies
- Contract performance: To deliver courses and advisory services you have enrolled in
- Legitimate interest: For website analytics and internal service improvement
- Legal obligation: Where required by Thai law
4. How We Use Your Data
- To respond to enquiries submitted through the contact form
- To process course enrolments and deliver course materials
- To schedule and conduct live sessions and advisory calls
- To send course-related communications (session reminders, updates)
- To improve our website and course content using anonymised usage data
- To fulfil legal and regulatory obligations under Thai law
We do not use your personal data for advertising purposes, and we do not sell your information to third parties.
5. Data Sharing
We do not sell, rent, or trade personal data. We may share limited information with:
- Licensed financial planning advisors who deliver advisory sessions (bound by confidentiality obligations)
- Service providers who support website operation and course delivery (under data processing agreements)
- Regulatory authorities, if required by Thai law
6. Data Retention
We retain personal information for the following periods:
- Contact form submissions: up to 12 months unless enrolment follows
- Course enrolment records: up to 5 years for financial and administrative purposes
- Advisory session notes: retained for the duration of the course engagement, then deleted unless extended with consent
- Website analytics data: aggregated and anonymised after 26 months
7. Data Protection Measures
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, or disclosure. These include encrypted data transmission (HTTPS), access controls limiting staff access to personal data on a need-to-know basis, and regular review of our data handling practices. In the event of a data breach that is likely to affect your rights, we will notify you and the relevant Thai authority as required under the PDPA.
8. Cookies
Our website uses cookies to support basic functionality and to understand how visitors use the site. You can manage your cookie preferences at any time via our Cookie Policy page. Essential cookies cannot be disabled as they are required for the site to function.
9. Your Rights Under the PDPA
As a data subject under Thailand's Personal Data Protection Act, you have the following rights:
- Right to be informed about how your data is used
- Right to access your personal data held by us
- Right to rectification of inaccurate data
- Right to erasure (subject to legal retention requirements)
- Right to restrict processing in certain circumstances
- Right to data portability where technically feasible
- Right to object to processing based on legitimate interest
- Right to withdraw consent at any time (without affecting prior processing)
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
If you believe your rights have not been respected, you have the right to lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand.
10. Third-Party Links
Our website may contain links to external resources. We are not responsible for the privacy practices of third-party websites and recommend reviewing their privacy policies separately.
11. Children's Privacy
Our courses are designed for adults aged 40 and over. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data through our site, please contact us and we will remove it promptly.
12. International Data Transfers
We primarily process and store data within Thailand. Where any data is processed outside Thailand (for example, via cloud service providers), we ensure appropriate safeguards are in place in accordance with the PDPA.
13. Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will update the "Last Updated" date at the top of this page. Continued use of our website or services after changes are published constitutes acceptance of the revised Policy.
14. Contact Information
Data Controller: Samruay
Address: 82 Rama III Road, Yan Nawa, Bangkok 10120, Thailand
Email: [email protected]
Phone: +66 93-827-1564