Privacy Policy
Garuda Wing · Last Updated: 15 February 2025 · Effective Date: 15 February 2025
Data Controller: Garuda Wing, 217 Lat Phrao Road, Chatuchak, Bangkok 10900, Thailand. For privacy enquiries: [email protected]
1. Introduction
Garuda Wing operates as a financial education provider in Bangkok, Thailand. We are committed to protecting the personal information of our participants, enquirers, and website visitors. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have under applicable data protection law — including Thailand's Personal Data Protection Act B.E. 2562 (PDPA).
This policy applies to personal data collected through our website, our contact forms, our educational programmes, and any other interaction with Garuda Wing.
2. Data We Collect
2.1 Information You Provide Directly
- Full name
- Email address
- Telephone number (where provided)
- Enquiry content submitted through our contact form
- Programme enrolment details
- Personal financial information shared during mentorship or group sessions (held in strict confidence)
2.2 Information Collected Automatically
- IP address and browser type
- Pages visited and time spent on our website
- Cookie data (see our Cookie Policy)
- Referring URLs and device type
3. How We Use Your Data
- To respond to enquiries and provide information about our programmes
- To process enrolments and administer programme delivery
- To communicate programme schedule updates or relevant educational content
- To improve our website and educational offerings based on usage patterns
- To comply with applicable Thai legal and regulatory requirements
- To manage our operational and administrative records
We do not use personal data to sell or market third-party financial products. We do not share personal data with financial institutions, insurers, or brokers.
4. Legal Basis for Processing
- Contract performance: Processing necessary for delivering a programme you have enrolled in
- Consent: Where you have explicitly agreed — for example, to receive programme updates by email
- Legitimate interests: For general website operation and service improvement, balanced against your rights
- Legal compliance: Where required by Thai law
5. Data Retention
We retain your personal data only for as long as necessary for the purposes described above. In general:
- Enquiry data: retained for 12 months from the date of initial contact unless enrolment follows
- Enrolment and programme records: retained for 3 years following programme completion
- Financial information shared in sessions: retained only for the duration of active programme engagement, then deleted or anonymised
- Website analytics data: retained for 26 months
6. Data Sharing
We do not sell your personal data. We may share data with:
- Service providers: Third parties who assist with website hosting, email delivery, and analytics — under contractual data protection obligations
- Legal authorities: Where required by Thai law or a court order
Any third-party service providers used by Garuda Wing are contractually required to process data only on our instructions and in accordance with applicable law.
7. Data Security
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:
- TLS encryption for data transmitted via our website
- Access controls limiting data access to authorised staff only
- Secure storage practices for programme records
- Regular review of our data handling procedures
In the event of a personal data breach that poses a risk to your rights, we will notify you and the relevant supervisory authority as required under Thai PDPA provisions.
8. Cookies
Our website uses cookies to support functionality and to understand how visitors use our pages. For full details, please see our Cookie Policy.
9. Your Rights Under Thai PDPA
Under the Personal Data Protection Act B.E. 2562, you have the following rights:
- Right of access: To request a copy of 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 where no legal basis for retention exists
- Right to data portability: To receive your data in a structured, machine-readable format
- Right to object: To object to processing based on legitimate interests
- Right to withdraw consent: At any time, where consent is the legal basis for processing
- Right to restrict processing: To request that we pause processing in certain circumstances
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
You may also lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) of Thailand if you believe your rights have not been respected.
10. 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 read their privacy policies independently.
11. Children's Privacy
Our programmes are designed for adults aged forty and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that data has been collected from a minor, it will be deleted promptly.
12. International Transfers
Your data is primarily stored and processed in Thailand. Where any processing involves servers outside Thailand — for example, via cloud-based email or analytics providers — we ensure appropriate safeguards are in place as required by Thai PDPA.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by updating the "Last Updated" date at the top of this page. Continued use of our services after such changes constitutes acceptance of the updated policy.
14. Contact
For any privacy-related questions or to exercise your rights:
- Email: [email protected]
- Post: Garuda Wing, 217 Lat Phrao Road, Chatuchak, Bangkok 10900, Thailand