Privacy Policy

1. Our role and the merchant’s role

For website visitor data and merchant account data, we act as the data controller.

For member data held inside a merchant’s tenant, that merchant is the data controller and we act as the data processor following the merchant’s instructions. If you are a member wishing to exercise your rights, please contact the merchant whose programme you joined first.

2. Data we collect

• Merchant account data: email address, one-way hashed password, business name, phone number, logo, and how you heard about us.
• Billing data: plan, billing cycle, invoice history, and payment-provider reference IDs. We do not store full card numbers in our own systems.
• Member data: display name, profile image, point balance, tier, coupon redemption history, bookings, and interaction with merchant messages.
• LINE user identifiers: we never store raw LINE user IDs. We store a SHA-256 hash scoped to a single tenant, so identifiers cannot be matched across merchants.
• Website contact form data: name, business name, email, phone number, business type, and message.
• Technical and usage data: IP address, browser type, access time, pages viewed, sign-up funnel events, and campaign parameters (utm_source, utm_medium, utm_campaign, utm_term, utm_content, ref).
• Security logs: sign-in history, changes to important settings, and audit logs.

3. Purposes and legal bases

• Contract performance: creating and maintaining accounts, providing the platform, invoicing, and technical support.
• Legitimate interests: securing the platform, preventing fraud and abuse, analysing and improving the Service in aggregate, and measuring our own marketing campaigns.
• Legal obligation: accounting and tax records, and responding to lawful requests from authorities.
• Consent: marketing communications about our Service, which you may withdraw at any time.

4. Cookies and similar technologies

• Strictly necessary cookies: session state and CSRF protection. The Service cannot function if these are blocked.
• Browser storage: we use localStorage/sessionStorage for your selected language and an anonymous identifier used to measure the sign-up funnel.
• Third-party security service: Cloudflare Turnstile provides human verification on the sign-up and sign-in pages.
• Analytics cookies (Google Analytics): used to collect aggregate usage statistics, such as visitor counts and which pages are used, so we can improve the Service. They are set only after you click "Accept" on the cookie banner. You can withdraw consent at any time through the "Cookie settings" link in the site footer, or by clearing this site's data in your browser.

5. Disclosure and sub-processors

We do not sell personal data. We disclose data only as necessary to providers acting on our behalf under data processing agreements:

• LINE Corporation — for LINE Official Account, LINE Login, and LINE Mini App functionality.
• Cloud infrastructure and database providers — for storage and processing.
• Transactional email providers — for verification emails, password reset emails, and notifications.
• Payment providers — for plan subscription and recurring billing.
• AI model providers — for SaanjaiAi features, sending only the data needed to produce the output.
• Professional advisers, regulators, or courts — where disclosure is legally required.

6. International transfers

Some providers may process data outside Thailand. Where that happens, we put appropriate safeguards in place as required by the PDPA, such as standard contractual data protection clauses.

7. Retention

• Account and tenant data: kept for the duration of the subscription and no more than 90 days after termination, unless a longer period is legally required.
• Accounting and tax records: kept for at least 5 years as required by law.
• System and audit logs: kept for no more than 12 months, unless needed for a security investigation.
• Contact form submissions: kept for no more than 24 months from the last contact.
• At the end of the retention period we delete or anonymise the data.

8. Security measures

• Data in transit is encrypted with HTTPS/TLS, and access follows the least-privilege principle.
• Passwords are stored as one-way hashes, never in readable form.
• Tenant data is isolated — every data access is scoped to the owning tenant.
• Sign-in rate limiting and human verification reduce credential-guessing risk.
• LINE user identifiers are stored as tenant-scoped hashes, and identifiers or tokens are never written to logs.
• Audit logs record changes to important settings.

9. Your rights

Under the PDPA you have the following rights. We respond within 30 days of receiving a complete request.

• Access — request access to and a copy of your personal data.
• Rectification — request correction of inaccurate or outdated data.
• Erasure — request deletion where the data is no longer needed.
• Restriction — request that we suspend use of your data.
• Objection — object to collection, use, or disclosure.
• Portability — request your data in a machine-readable format.
• Withdraw consent — without affecting processing already lawfully carried out.
• Complaint — lodge a complaint with the Personal Data Protection Committee office.

10. Children’s data

The Service is not designed for merchants under 20 years of age. If a merchant collects minors’ data in its loyalty programme, that merchant is responsible for obtaining guardian consent as required by law.

11. Data breach notification

If a personal data breach occurs that poses a risk to individuals’ rights and freedoms, we will notify the Personal Data Protection Committee office within 72 hours of becoming aware of it, and notify affected individuals as required by law.

12. Changes to this policy

We may update this policy from time to time. The version and effective date are published on this page, and we notify you by email or in the Merchant Dashboard for material changes.