This policy was last updated: 28 May 2021.
Paul Poole (South East Asia) Co., Ltd. (‘PP(SEA)CL’) may change this policy from time to time by updating this page. On each visit to the website you should refer to this page to ensure that you are aware of and accept any changes.
PP(SEA)CL recognises the trust you place in us when you share personal information with us. We are committed to being open, honest and transparent with our use of personal data.
We will take all reasonable steps to ensure that personal information is safeguarded and kept in accordance with data protection law.
By providing us with your data, you warrant that you are over 13 years of age.
PP(SEA)CL is registered in Thailand under Company Registration Number 0105547088942. Our registered office address is at 198 Tanou Road, Bovernives, Pranakorn, Bangkok, 10200, Thailand.
Our website at www.paulpoole.co.th is designed to promote our marketing agency and consultancy services as well as well as marketing opportunities.
Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law. For any issues relating to data protection the person responsible is Paul Poole. You can contact him in relation to data protection matters by email to firstname.lastname@example.org.
Personal information is any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal information about you when we engage with you.
This will include:
We use different methods to collect data from and about you, through:
The Contact Form on our website is used to collect your name, job title, company name, email address and telephone number as well as your message, so that we can respond to your communications and provide details of our services and deal with general company enquiries. Data is held on the grounds of being legitimate to our business interests.
Calls to us may be recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a client of ours.
You may give us your data by filling in forms or by corresponding with us face-to-face, by post, or through chat or social media. This includes personal data you provide when you: sign up to receive our newsletter; make enquiries or request information be sent to you; order our services; ask for information to be sent to you; engage with us on social media; enter a competition, promotion or survey; contact us direct; or leave comments or reviews on our services.
We use social media to engage with users and link to our LinkedIn, Twitter, Facebook pages and YouTube channel. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.LinkedIn: https://www.linkedin.com/legal/privacy-policy
We may ask you for a testimonial in relation to our services that may be used on our website or social media. Your name and company may be used. Data is only published on the basis of valid consent obtained from you.
When you visit our website we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us.
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We do not market this website at those under 18 years old. Consistent with the GDPR (EU) and PDPA (TH) we will never knowingly request personally identifiable information from anyone under the age of 16 years old.
From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law.
We may receive personal data relating to: your identity and contact data from data partners; and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.
Thailand data protection law requires us to have a “legal basis” for processing personal data.
The legal basis we rely on are:
We may use the information we collect from you in the following ways:
Users contacting this website and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
When we use our legitimate interests as the legal basis for processing your personal information, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations.
We may send some Clients status reports in relation to companies we have contacted on their behalf to see if they are interested in sponsorship or partnership marketing campaigns. Contact details are kept on an excel spreadsheet and include details of the company name, name and title of contact and a summary of the status.
We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR (EU) and PDPA (TH). You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller.
We may carry out direct marketing by email, telephone, text (SMS/MMS/IM) or post.
You have the option not to give consent and to withdraw consent at any time from future marketing communications. You may withdraw your consent for us to contact you by emailing us at email@example.com. We may continue to contact you if there is another lawful basis to do so.
Non-personally identifiable information may be provided to other third parties for marketing, advertising or other uses.
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by email or telephone.
PP(SEA)CL uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.
Payments handled on our premises shall comply with the standard procedures and requirements as laid down by law to ensure that personal data is kept secure.
If we purchase products or services from you we will keep your account details you send us as part of your invoices on our files. A record of your account details will also be kept with our banking services provider.
We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such system and are required to keep the information confidential.
We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email. Any transmission is at your own risk.
Our website is hosted by CloudHost https://cloudhost.in.th. Any information that you supply to us may be stored and processed by our servers located in Thailand. Your data may be transferred in accordance with the relevant data protection laws.
PP(SEA)CL recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:
Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) to PP(SEA)CL. We will act on any such request within a reasonable timeframe during business operating hours, which legally require us to respond within one month of receiving the request and necessary information. A subject access request can be made by emailing us at firstname.lastname@example.org.
Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect. We will act on any such request within a reasonable timeframe during business operating hours.
Data subjects have the right to request us to delete personal information from our systems without giving any reason and at any time. We will act on any such request within a reasonable timeframe during business operating hours.
Data subjects have the right to request rectification or erasure of personal data in the following circumstances:
We will act on any such request within a reasonable timeframe during business operating hours.
Data subjects have the right to obtain and request the transfer of their data to different service providers. We will act on any such request within a reasonable timeframe during business operating hours.
Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds. We will act on any such objection within a reasonable timeframe during business operating hours.
We do not use any automated processing that results in any automated decision based on a data subject’s personal information.
If you wish to invoke any of these rights, you should contact the person responsible for data protection by email to email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We will report any unlawful breach of data as required by the GDPR (EU) and PDPA (TH) within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication.
If you have any concerns about how we handle your data, you can contact the Data Controller by email to firstname.lastname@example.org.
If you want to raise a concern about the use of your data, you can contact us by email to email@example.com.
General Data Protection Regulation, European Union: GDPR (EU) and Personal Data Protection Act, Thailand: PDPA (TH)
Thailand’s PDPA comes into effect on 31 May 2021 – almost exactly three years after the EU set benchmarks for global data privacy laws via GDPR adoption.