Privacy Policy — Thlunarhub Financial Education

Thlunarhub ("we", "us", "our") is committed to handling personal information with care and transparency. This policy explains what data we collect, why we collect it, how we use it, and what rights you have in relation to it. It applies to all clients and visitors who interact with our services or website at thlunarhub.

Our operations are based in Chiang Mai, Thailand, and this policy is aligned with Thailand's Personal Data Protection Act B.E. 2562 (PDPA). Where clients are resident in jurisdictions with their own data protection legislation, we apply equivalent care.

1. Data We Collect

We collect personal data in the following circumstances:

Contact enquiries: Name, email address, phone number, and any information you choose to include in your message when using our contact form or reaching us by phone or email.
Programme delivery: Financial background information, family circumstances, income and savings details shared during educational sessions — provided by you voluntarily for the purpose of the programme.
Website usage: Technical information such as browser type, device type, pages visited, and time on page — collected via analytics cookies where consent has been given.

We do not collect sensitive financial account numbers, passport details, or identification documents unless a specific programme requires it and you have been informed in advance.

2. Legal Basis for Processing

We process personal data under the following legal bases:

Contract performance: To deliver the educational programme you have enrolled in.
Legitimate interest: To manage our practice, respond to enquiries, and maintain records of completed programmes.
Consent: For optional analytics cookies and marketing communications, where you have explicitly agreed.

3. How We Use Your Data

To respond to your enquiries and provide requested information
To deliver and document programme sessions
To produce written materials (guides, roadmaps, reports) specific to your situation
To maintain a record of our engagement for quality and continuity purposes
To send occasional programme-related communications where relevant
To improve our services based on aggregated, anonymised usage patterns

We do not use your personal data for marketing to third parties, and we do not sell, rent, or trade personal information under any circumstances.

4. Data Retention

Contact enquiry data is retained for 12 months. Programme session materials and client records are retained for 5 years following completion of a programme, unless you request earlier deletion. Website analytics data is retained for 24 months before deletion.

5. Data Security

We take reasonable technical and organisational measures to protect your personal information. Session notes and client documents are stored in password-protected systems with access restricted to the relevant educator. Physical documents are stored in locked office facilities at our Chiang Mai premises.

In the event of a data breach affecting your personal information, we will notify you as soon as reasonably practicable and take steps to limit any harm.

6. Sharing with Third Parties

We do not share your personal data with third parties except in the following limited circumstances:

Where required by Thai law or regulatory authority
With professional advisers (e.g., legal counsel) bound by confidentiality obligations
With technology service providers who process data on our behalf under written data processing agreements (e.g., our email service provider)

7. Cookies

Our website uses cookies. Essential cookies are required for basic functionality. Optional analytics and preference cookies are used only where you have given consent via our cookie banner. For full details, please see our Cookie Policy.

8. Your Rights

Under the Thai PDPA, you have the following rights:

Right of access: To request a copy of the personal data we hold about you.
Right to rectification: To request correction of inaccurate or incomplete data.
Right to erasure: To request deletion of your data in certain circumstances.
Right to data portability: To receive your data in a structured, machine-readable format.
Right to object: To object to certain types of processing, including direct marketing.
Right to withdraw consent: Where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at privacy@thlunarhub. We will respond within 30 days.

9. Children

Our services are provided to adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently received data from a minor, please contact us immediately and we will delete it.

10. Third-Party Links

Our website may occasionally contain links to external websites. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies independently.

11. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The "Last Updated" date at the top of this page will reflect any changes. Continued use of our services after changes constitute acceptance of the updated policy.

12. Contact

If you have questions about this policy or wish to exercise your data rights, please contact us:

Email: privacy@thlunarhub
Post: Thlunarhub, 62 Chiang Mai–Lamphun Road, Wat Ket, Mueang Chiang Mai, Chiang Mai 50000, Thailand