Privacy Policy

1. Data We Collect

We collect personal data in the following circumstances:

• Enquiry and registration forms — name, email address, telephone number (optional), and any message content you include.
• Session registration — name, email address, organisation name (optional), and the session or product you are booking.
• Website usage — anonymised analytics data via cookies (if consent is given), including pages visited, time on site, and browser type. No personally identifiable information is collected via analytics unless you submit a form.
• Communications — content of emails or messages sent to us.

We do not collect sensitive personal data such as financial account details, health information, or government identification numbers.

2. Legal Basis for Processing

We process personal data on the following legal bases under Thailand's Personal Data Protection Act B.E. 2562 (PDPA):

• Contract performance — to fulfil a booking, deliver the HR Onboarding Reference Kit, or respond to an enquiry.
• Legitimate interests — to improve our sessions based on feedback, maintain records of attendees for operational purposes, and communicate relevant session updates.
• Consent — for optional analytics cookies and any direct marketing communications. Consent can be withdrawn at any time.

3. How We Use Personal Data

• Responding to enquiries and confirming bookings
• Delivering session materials and the HR Onboarding Reference Kit
• Sending administrative communications related to booked sessions (date reminders, venue details, follow-up availability)
• Processing post-session feedback forms
• Improving session content based on aggregated, anonymised participant data
• Complying with applicable legal obligations

We do not use personal data for unsolicited marketing or share it with third parties for advertising purposes.

4. Data Sharing

We do not sell or rent personal data. We may share data in the following limited circumstances:

• Service providers — email hosting and website infrastructure providers who process data on our behalf under appropriate data processing agreements.
• Analytics — anonymised, aggregated website usage data may be processed by a third-party analytics service (only if you have consented to analytics cookies).
• Legal requirements — where disclosure is required by Thai law, court order, or regulatory authority.

5. Data Retention

• Enquiry and contact data — retained for 24 months from the date of last contact, then deleted unless a booking has been made.
• Session booking records — retained for 36 months for operational records, then deleted or anonymised.
• HR Onboarding Reference Kit purchase records — retained for 5 years for accounting and legal compliance purposes.
• Post-session feedback — retained in anonymised form only; personally identifiable data deleted within 90 days.

6. Data Protection Measures

• Data is stored on servers located in Thailand.
• Access to personal data is restricted to Pensava staff who need it to perform their role.
• Our website uses HTTPS encryption for all data transmission.
• In the event of a data breach affecting personal data, we will notify affected individuals within the timeframes required by Thailand's PDPA.
• Physical records containing personal data (such as session registration forms) are stored in a locked cabinet and shredded after the retention period.

7. Cookies

Our website uses cookies. For full details of the types of cookies we use, their purposes and how to manage them, please see our Cookie Policy. In summary:

• Essential cookies — necessary for the website to function; always active.
• Analytics cookies — collect anonymised usage data to help us improve the site; active only with your consent.
• Preference cookies — remember your cookie consent choice; active only with your consent.

8. Your Rights

Under Thailand's Personal Data Protection Act B.E. 2562, 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 — request correction of inaccurate or incomplete data.
• Right to erasure — request deletion of your data in certain circumstances.
• Right to data portability — request your data in a portable format where technically feasible.
• Right to object — object to processing based on legitimate interests.
• Right to withdraw consent — withdraw consent for optional processing at any time without affecting prior processing.
• Right to lodge a complaint — contact the Office of the Personal Data Protection Committee (PDPC) in Thailand if you believe your rights have not been respected.

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

9. Third-Party Links

Our website may contain links to external websites, including official Thai government portals referenced in our session materials. We are not responsible for the privacy practices of those sites and encourage you to review their policies before submitting personal data to them.

10. Children's Privacy

Pensava's sessions and services are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted data to us, please contact [email protected] and we will delete it promptly.

11. Policy Updates

We may update this policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page. For significant changes, we will notify registered participants by email where practicable. Continued use of our website or services after changes have been posted constitutes acceptance of the updated policy.