Privacy Policy

1. Introduction

Calmway ("we", "us", "our") is committed to handling your personal data carefully and transparently. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have in relation to it.

This policy applies to all personal data collected through our website at calmwaydas.biz, our enrolment and enquiry processes, and our delivery of educational services including the Listening & Understanding Class, Family File Organiser, and Steady Support Membership.

Calmway operates under Thai law, including the Personal Data Protection Act B.E. 2562 (PDPA). If you have questions about this policy, please contact us at [email protected].

2. Data We Collect

2.1 Data you provide directly

• Full name and email address (required for enquiries and enrolment)
• Phone number (optional, provided at your choice)
• Message content from our contact form
• Payment information (processed by our payment provider; we do not store card details)

2.2 Data collected automatically

• Browser type and device information
• Pages visited and time spent on the site (via analytics cookies, where consented)
• IP address (anonymised where possible)

2.3 Legal basis for processing

We process your data on the following legal bases under the PDPA:

• Contractual necessity: processing required to administer your enrolment or respond to an enquiry
• Consent: for analytics cookies and optional marketing communications
• Legitimate interests: for improving our services and maintaining site security

2.4 Retention periods

Enquiry and enrolment data is retained for up to three years following last contact. Payment records are kept for seven years as required by Thai accounting law. Analytics data is retained for 26 months.

3. How We Use Your Data

• Responding to enquiries and providing requested information about our offerings
• Administering enrolments and delivering purchased services
• Sending session details, recordings, and membership resources to enrolled participants
• Improving our website based on aggregated, anonymised usage data
• Complying with applicable Thai law

We do not use your personal data for automated decision-making or profiling.

Marketing: We do not send marketing communications unless you have actively opted in. You may withdraw consent at any time by emailing [email protected].

4. Data Sharing

We do not sell your personal data. We share data only with:

• Payment processors: for secure handling of transactions
• Email delivery services: used to send session details and membership resources
• Analytics services: only where you have consented to analytics cookies
• Legal authorities: where required by Thai law or valid legal process

All third-party processors are required to handle data in accordance with applicable data protection standards.

5. Data Protection Measures

• All data transmitted between your browser and our website is protected by TLS encryption
• Access to personal data is restricted to team members who need it to carry out their work
• We conduct periodic reviews of our data handling practices
• In the event of a data breach affecting your rights, we will notify you and the relevant authority within the timeframe required by the PDPA

6. Cookies

We use essential cookies required for basic site function, and optional analytics and preference cookies where you have consented. For full details, please see our Cookie Policy.

7. Your Rights

Under the PDPA you have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data (subject to legal retention obligations)
• Request restriction of processing in certain circumstances
• Object to processing based on legitimate interests
• Withdraw consent at any time where processing is based on consent
• Lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand

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

8. Third-Party Links

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

9. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data to us, please contact us and we will delete it promptly.

10. Changes to This Policy

We may update this policy from time to time. We will post the updated version on this page with a revised "Last Updated" date. Where changes are material, we will notify enrolled participants by email.

11. Contact

Data Controller: Calmway

309 Sukhumvit Road, North Pattaya, Chonburi 20150, Thailand

Email: [email protected]

Phone: +66 38 415 727