Privacy Policy
Last Updated: 28 March 2025 ยท Effective: 28 March 2025
1. Introduction
Thornvale ("we", "us", "our") is committed to protecting the personal information of everyone who interacts with our educational programs and this website. This policy explains what data we collect, why we collect it, how we use it, and the rights available to you under Thailand's Personal Data Protection Act B.E. 2562 (PDPA) and applicable regulations.
This policy applies to all data collected through our website at thfunmetric, our contact forms, and during program delivery at our Bangkok office.
For questions regarding this policy, contact: privacy@thfunmetric
2. Data We Collect
We collect only the personal information necessary to provide our educational services and respond to enquiries. This includes:
- Name and contact details (email address, phone number)
- Postal address where provided
- Financial background information shared voluntarily during programs (used solely for educational purposes)
- Website usage data via analytics cookies (with consent)
- Communications sent to us by email or contact form
We do not collect sensitive financial account details, government identification numbers, or payment card information through our website.
3. How We Collect Data
- Contact forms submitted on our website
- Email correspondence
- In-person or remote program sessions (participant-provided information)
- Cookies and website analytics tools (with consent)
4. Legal Basis for Processing
We process personal data on the following legal bases under the PDPA:
- Consent โ for marketing communications and non-essential cookies
- Contract performance โ to deliver enrolled programs and manage bookings
- Legitimate interests โ to respond to enquiries, improve our services, and maintain records
- Legal obligation โ where required by Thai law
5. How We Use Your Data
- To respond to enquiries and manage program enrolment
- To deliver program sessions and provide associated materials
- To maintain records of participation
- To send relevant program information where you have consented
- To improve our website and educational content
- To comply with legal and regulatory obligations in Thailand
6. Data Retention
We retain personal data only for as long as necessary:
- Enquiry data: up to 12 months from last contact
- Program participant records: up to 5 years from program completion
- Financial background information shared in sessions: retained only for program duration unless participant requests otherwise
- Website analytics data: up to 26 months (cookie-dependent)
7. Data Sharing
Thornvale does not sell, rent, or share personal data with third parties for commercial purposes. We may share data with:
- Service providers who assist with website hosting and email delivery โ under data processing agreements
- Analytics providers (e.g. Google Analytics) โ where analytics cookies are accepted
- Regulatory authorities โ where required by Thai law
We do not share data with banks, insurance companies, or financial product providers.
8. Data Protection Measures
- Encrypted transmission (HTTPS) for all website communications
- Access to personal data restricted to authorised personnel
- Regular review of data handling practices
- Incident response procedures in place for potential data breaches
In the event of a data breach affecting your rights, we will notify affected individuals and, where required, the Personal Data Protection Committee within the timeframes specified under Thai law.
9. Cookies
We use cookies to improve website functionality and understand usage patterns. For details on the types of cookies used and how to manage them, see our Cookie Policy.
10. Your Rights Under Thai PDPA
As a data subject under Thailand's PDPA, you have the right to:
- Access personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data (subject to legal retention requirements)
- Object to processing based on legitimate interests
- Withdraw consent at any time without affecting lawfulness of prior processing
- Request data portability where technically feasible
- Lodge a complaint with the Personal Data Protection Committee of Thailand
To exercise any of these rights, contact us at privacy@thfunmetric. We will respond within 30 days.
11. Third-Party Links
Our website may contain links to external resources. We are not responsible for the privacy practices of third-party websites and encourage you to review their policies independently.
12. Children's Privacy
Our programs are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.
13. Policy Updates
We may update this policy from time to time to reflect changes in our practices or applicable law. Material changes will be communicated via our website. Continued use of our services following an update constitutes acceptance of the revised policy.
14. Contact
Data Controller: Thornvale
Address: 73 Phra Athit Road, Chana Songkhram, Phra Nakhon, Bangkok 10200, Thailand
Email: privacy@thfunmetric
Phone: +66 2 282 7461