Privacy Policy

1. Introduction and Scope

Somboon Panya ("we", "us", "our") is a financial education practice based at 89 Sukhumvit Soi 24, Khlong Toei, Bangkok 10110, Thailand. This Privacy Policy applies to information collected through our website at somboonen.club and through our program registration and enquiry processes.

By using our website or submitting your details to us, you agree to the practices described in this policy. If you have questions about how we handle your data, please contact us at [email protected].

2. Information We Collect

We may collect the following types of personal information:

• Contact details: Name, email address, and telephone number provided through our contact form or program registration.
• Enquiry content: Messages and questions you send us, which may include information about your financial situation or planning goals.
• Usage data: Technical information including browser type, pages visited, and time spent on our website, collected via analytics tools if you consent to analytics cookies.
• Cookie data: Information stored in cookies, as described in our Cookie Policy.

We do not collect sensitive personal data such as financial account numbers, government identification numbers, or health information through our website. Any sensitive information discussed during program sessions is handled under strict confidentiality protocols.

3. How We Use Your Information

We use the personal information you provide for the following purposes:

• To respond to enquiries about our programs
• To process program registrations and communicate session details
• To send information about upcoming programs if you have expressed interest (you may opt out at any time)
• To improve our website and program content through aggregated, anonymised analytics
• To comply with applicable Thai legal requirements

We do not sell your personal information to any third party. We do not share your details with financial product providers, advertisers, or any commercial third parties.

4. Legal Basis for Processing

Our processing of your personal data rests on the following legal bases under Thailand's Personal Data Protection Act (PDPA) B.E. 2562 (2019):

• Consent: For analytics cookies and marketing communications, where you have given explicit consent.
• Contract: For processing necessary to respond to your enquiries and fulfil program registrations.
• Legitimate interests: For website security and fraud prevention, where our interests do not override your rights.
• Legal obligation: Where Thai law requires us to retain or disclose information.

5. Data Retention

We retain personal data only for as long as necessary for the purpose it was collected:

• Enquiry records: up to 12 months after the last contact, unless you have enrolled in a program
• Program participant records: up to 3 years after program completion, for follow-up and record-keeping
• Marketing contact records: until you withdraw consent or we are asked to delete them
• Analytics data: aggregated and anonymised after 26 months

6. Data Protection Measures

We implement reasonable and appropriate security measures to protect the personal information we hold:

• Website data transmitted over secure HTTPS connections
• Access to personal records restricted to staff with a legitimate need
• Regular review of data handling practices
• Physical records stored securely at our Bangkok office

In the event of a data breach affecting your personal information, we will notify you and the relevant Thai supervisory authority as required by law.

7. Cookies

Our website uses cookies to function correctly and to help us understand how visitors use the site. Essential cookies are always active. Analytics and preference cookies are only used if you consent. For full details, please see our Cookie Policy.

8. Third-Party Services

We may use the following third-party services that process data on our behalf:

• Google Analytics (if analytics cookies are accepted): anonymous website usage statistics
• Email service providers: used to deliver communications securely
• Web hosting provider: Thai-based hosting with appropriate data handling agreements

We do not share personal data with these providers beyond what is necessary for the service they provide. Our website may include links to external sites. We are not responsible for the privacy practices of those sites.

9. Your Rights

Under Thailand's Personal Data Protection Act (PDPA), you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your data, subject to legal retention requirements
• Right to data portability: Request your data in a portable format where applicable
• Right to object: Object to processing based on legitimate interests or for marketing purposes
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) of Thailand.

10. Children's Privacy

Our programs and website are intended for adults aged 18 and above. We do not knowingly collect personal information from anyone under 18. If we become aware that we have inadvertently received data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or Thai data protection law. When we make material changes, we will update the "Last Updated" date at the top of this page. Continued use of our website after any changes constitutes acceptance of the updated policy.