Privacy Policy
Last Updated: 10 June 2025 | Effective: 10 June 2025
1. Introduction
Pensara ("we," "us," or "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect information when you use our website or engage our retirement document organisation services. It applies to all clients and website visitors.
Pensara operates from 64 Charoen Muang Road, Wat Ket, Chiang Mai 50000, Thailand. Questions about this policy may be sent to [email protected].
2. Data We Collect
We collect personal data in the following ways:
- Contact form submissions: name, email address, and optionally phone number and message content.
- Session scheduling: name, contact details, preferred date and delivery format (in-person, home visit, or online).
- Session notes: during sessions, we may make notes relating to the documents you bring for organisational purposes only.
- Website analytics: anonymised data about page visits via analytics cookies (if consent is given).
- Cookie preferences: your consent choices are stored locally in your browser.
We do not collect sensitive financial data, document content, or account numbers.
Legal basis for processing: consent (contact forms, marketing); contract (service delivery); legitimate interest (website improvement).
Retention: Contact enquiries are retained for 12 months. Session notes are retained for 24 months unless you request earlier deletion. Analytics data is anonymised and retained for 26 months.
3. How We Use Your Data
- To respond to your enquiries and schedule sessions
- To deliver the retirement document organisation service you have booked
- To send session reminders and follow-up notes
- To improve our website and session materials based on anonymised usage data
- To comply with applicable Thai law and our contractual obligations
We do not use your data for automated decision-making or profiling. We do not sell your data. We do not send unsolicited marketing without your explicit consent.
4. Data Sharing
We do not share personal data with third parties for commercial purposes. Limited sharing may occur in the following situations:
- Service providers: our email and scheduling tools (used to communicate with you). These providers are contractually bound to protect your data.
- Analytics: anonymised website data may be processed by a third-party analytics platform if analytics cookies are accepted.
- Legal obligation: we may disclose data if required to do so by Thai law or a competent authority.
5. Data Protection Measures
- All data is stored on secured servers with restricted access controls.
- Session notes are stored on encrypted devices accessible only to the relevant Pensara consultant.
- We review our data handling practices regularly.
- In the event of a data breach that poses risk to you, we will notify you without undue delay.
6. Cookies
Our website uses cookies to function correctly and, with your consent, to analyse traffic. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.
7. Your Rights
Under Thailand's Personal Data Protection Act B.E. 2562 (PDPA), you have the following rights regarding your personal data:
- Right to access — request a copy of the personal data we hold about you.
- Right to rectification — ask us to correct inaccurate data.
- Right to erasure — request deletion of your data where we have no overriding reason to retain it.
- Right to restrict processing — ask us to limit how we use your data in certain circumstances.
- Right to data portability — receive your data in a structured, machine-readable format.
- Right to object — object to processing carried out under legitimate interest.
- Right to withdraw consent — withdraw consent at any time where processing is based on consent.
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) in Thailand if you believe your data has been handled unlawfully.
8. Third-Party Links
Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend reading their policies before providing personal data.
9. Children's Privacy
Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.
10. Changes to This Policy
We may update this policy from time to time. The "Last Updated" date at the top of this page will reflect any changes. Continued use of our website or services after a change constitutes acceptance of the updated policy. For significant changes, we will notify active clients by email.
11. Contact
For privacy-related questions or to exercise your rights:
- Email: [email protected]
- Address: 64 Charoen Muang Road, Wat Ket, Chiang Mai 50000, Thailand
- Phone: +66 53 244 816