1. Data Controller
SMARTCOMM TRADE CO., LTD. ("SmartComm", "we", "us" or "our") is the data controller responsible for the personal data described in this Privacy Policy under Thailand's Personal Data Protection Act B.E. 2562 (2019) ("PDPA").
Our registered address is 219/2 Asoke Tower Building, Room No. 101, 2nd Floor, Soi Asoke, Khlong Toei Nuea, Watthana, Bangkok 10110, Thailand.
2. Personal Data We Collect
Depending on how you interact with us, we may collect:
- Identity and business information, such as your name, job title, company and industry.
- Contact information, such as your business email address, mailing address and any telephone number you choose to provide to us.
- Transaction and commercial information, including enquiries, quotations, orders, delivery details, invoices, payment status, warranties and support history. We do not retain full payment-card details when payment is handled by a payment provider.
- Communications, including messages, attachments, preferences and records of correspondence with our team.
- Technical and usage data, such as IP address, browser and device type, operating system, referring pages, pages viewed, timestamps and cookie identifiers.
- Marketing preferences and records of the consent you provide or withdraw.
Please do not provide sensitive personal data unless we specifically request it and have a lawful reason to process it.
3. How We Collect Personal Data
We collect personal data directly from you when you contact us, submit a website form, request a quotation, place an order, enter into a contract, request support, subscribe to communications or otherwise correspond with us. We also collect limited data automatically through server logs and cookies when you use our website.
We may receive information from your employer or colleagues, distributors, manufacturers, logistics and payment providers, business partners, public company records and other lawful public sources. If you provide another person's data, you must be authorized to do so and should make this Policy available to that person.
4. Purposes of Processing
We process personal data to:
- Respond to enquiries, assess requirements and prepare quotations or proposals.
- Process orders, payments, deliveries, returns, warranties and support requests.
- Manage customer, supplier and partner relationships and perform our contracts.
- Operate, secure, troubleshoot and improve our website, systems, products and services.
- Maintain business, accounting, tax, security and compliance records.
- Prevent fraud, misuse, security incidents and unlawful activity.
- Send relevant business marketing where permitted and manage your preferences.
- Establish, exercise or defend legal claims and comply with lawful requests.
5. Legal Bases
Under the PDPA, we rely on one or more of the following legal bases, as appropriate:
- Your consent, which you may withdraw at any time without affecting processing already carried out.
- Steps requested before entering into a contract and performance of a contract with you.
- Compliance with legal obligations, including tax, accounting and regulatory duties.
- Our legitimate interests or those of a third party, where those interests are not overridden by your fundamental rights, including operating and securing our business, responding to business enquiries and improving our services.
- The establishment, compliance, exercise or defense of legal claims, and other bases expressly permitted by applicable law.
8. International Data Transfers
Some service providers, manufacturers or business partners may process personal data outside Thailand. Where a transfer is made to a country that does not provide an adequate level of protection under the PDPA, we use a lawful transfer mechanism and appropriate safeguards, such as contractual protections, binding corporate rules where applicable, or your consent when required. We also limit transferred data to what is necessary.
9. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected and to meet contractual, legal, accounting, tax, warranty, security and dispute-resolution requirements. Retention periods depend on the type of record and applicable obligations. When data is no longer required, we securely delete or anonymize it unless continued retention is permitted or required by law.
10. Security Safeguards
We maintain reasonable administrative, technical and physical safeguards appropriate to the nature and risk of the data. These may include access controls, authentication, encryption where appropriate, system monitoring, backups, staff confidentiality obligations, supplier controls and incident-response procedures. No internet transmission or storage method is completely secure, but we review our safeguards and work to reduce risk.
11. Your Rights Under the PDPA
Subject to the conditions and exceptions in the PDPA, you may have the right to:
- Request access to and a copy of your personal data and information about its source.
- Request correction of inaccurate or incomplete data.
- Request deletion, destruction or anonymization of personal data.
- Request restriction or suspension of processing.
- Object to processing, including certain direct marketing and legitimate-interest processing.
- Receive or request transfer of eligible data in a machine-readable format.
- Withdraw consent at any time where processing relies on consent.
- Complain to Thailand's Personal Data Protection Committee or other competent authority.
To exercise a right, contact us using the details in section 16. We may verify your identity and may refuse or limit a request where permitted by law. We will respond within the period required by applicable law.
12. Children's Personal Data
Our website, products and services are intended for businesses and are not directed to children. We do not knowingly collect personal data from a child without the consent or authorization required by the PDPA. If you believe a child has provided personal data to us improperly, please contact us so that we can investigate and take appropriate action.
13. Third-Party Websites and Services
Our website may link to websites or services operated by third parties. Those parties control their own processing, and their privacy notices apply when you use their services. We are not responsible for their content, security or privacy practices. We encourage you to review their notices before providing personal data.
14. Marketing Communications
We may send information about relevant products, services and events where we have your consent or another lawful basis. You can opt out at any time by using an unsubscribe method included in the communication or by emailing us. Opting out of marketing does not stop necessary service, transaction, warranty or legal communications.
15. Changes to This Policy
We may update this Privacy Policy to reflect changes in our processing, services or legal obligations. We will post the revised Policy on this page and change the Last Updated date. If a change materially affects your rights or our use of personal data, we will provide additional notice or seek consent where required by law.
16. Contact Us
For privacy questions, requests or complaints, contact:
SMARTCOMM TRADE CO., LTD.
219/2 Asoke Tower Building, Room No. 101, 2nd Floor, Soi Asoke, Khlong Toei Nuea, Watthana, Bangkok 10110, Thailand
Email: info@smartcomm.co.th