Privacy Policy

1. Who We Are

Sommay Panya operates as a financial education provider based at 108 On Nut Soi 17, Suan Luang, Bangkok 10250, Thailand. For data-related enquiries, please contact us at [email protected].

2. Personal Data We Collect

Information you provide directly

• Name and contact details (email address, phone number) — submitted through enquiry forms or program enrollment
• Address — if provided during enrollment
• Financial context shared during programs — treated with strict confidentiality; not stored in our systems beyond what is necessary for program delivery

Information collected automatically

• Browser type, operating system, referring URL, and pages visited — collected via analytics tools if you have consented
• Cookies — see our Cookie Policy for full details
• IP address — retained briefly for security and analytics purposes

3. How We Use Your Personal Data

• Responding to enquiries and providing information about our programs
• Program enrollment, scheduling, and communications
• Preparing personalized written documents (Full Life Financial Narrative program)
• Sending program updates or feedback requests — only to participants who have enrolled
• Improving our website and programs through aggregate, anonymized analytics
• Compliance with Thai law and applicable regulations

Legal basis: We process data on the basis of consent (for optional communications and analytics), contractual necessity (for program delivery), and legitimate interest (for basic operational security and fraud prevention).

4. Data Retention

• Enquiry data: retained for up to 12 months unless you enroll in a program
• Participant records: retained for up to 3 years from the date of program completion
• Analytics data: aggregated and anonymized; individual records retained for up to 14 months
• Financial information shared in sessions: not stored beyond program delivery unless a written document is produced (retained securely for 3 years)

5. Data Sharing

We do not sell, rent, or trade personal data. We may share limited data with:

• Email service providers — for sending program communications (under data processing agreements)
• Analytics providers — only if you have consented to analytics cookies
• Thai regulatory authorities — only when legally required

We do not share data with banks, investment firms, or any financial product provider.

6. Data Security

• All data is stored on secured servers with access controls
• Staff access to personal data is limited to those who need it for their role
• We use encrypted email for sensitive communications where appropriate
• In the event of a data breach, we will notify affected individuals within 72 hours where possible

7. Cookies

Our website uses cookies for essential functionality and, with your consent, analytics. Full details are in our Cookie Policy. You can manage your cookie preferences at any time on that page.

8. Your Rights

Under Thailand's Personal Data Protection Act (PDPA) B.E. 2562, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your data (subject to legal retention requirements)
• Right to data portability: Request your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interest
• Right to withdraw consent: Withdraw consent for marketing or analytics at any time

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

9. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies independently.

10. Children's Privacy

Our programs are designed for adults aged 40 and older. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that a minor has submitted personal data, we will delete it promptly.

11. Changes to This Policy

We may update this policy periodically. When we do, we will update the "Last Updated" date at the top of this page. Continued use of our website or enrollment in programs after updates constitutes acceptance of the revised policy.

12. Contact Us

For any privacy-related questions or to exercise your rights:

• Email: [email protected]
• Address: 108 On Nut Soi 17, Suan Luang, Bangkok 10250, Thailand
• Phone: +66 2 742 8193

You also have the right to lodge a complaint with Thailand's Personal Data Protection Committee (PDPC) if you believe your rights have been violated.