Privacy Policy

1. Introduction

Eldergrove ("we", "us", "our") is committed to protecting the personal data of individuals who use our website and participate in our pension information and records support services. This Privacy Policy explains what personal 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 processed by Eldergrove in connection with our website at eldergrove.sbs and our educational and administrative programmes delivered in Bangkok, Thailand.

If you have any questions about this policy, please contact us at [email protected].

2. Personal Data We Collect

We collect the following categories of personal data, depending on how you interact with us:

2.1 Contact and Enquiry Data

• Full name
• Email address
• Telephone number (if provided voluntarily)
• Content of any messages or enquiries you send

2.2 Programme and Booking Data

• Programme or session selected
• Attendance records
• Feedback submitted after sessions

2.3 Website Usage Data

• IP address (anonymised where possible)
• Browser type and device type
• Pages visited and time spent on site
• Cookie preferences (see Section 6)

2.4 Legal Basis for Processing

We process personal data on the following lawful bases: (a) your consent, where given; (b) to perform a contract or take pre-contractual steps at your request (e.g. booking a session); (c) our legitimate interests in operating our business and improving our services; and (d) compliance with applicable law.

We retain contact and booking data for up to three years following your last interaction with us. Website usage data is retained for up to 12 months. Feedback data is retained for up to two years.

3. How We Use Personal Data

We use personal data for the following purposes:

• Responding to enquiries and booking requests
• Delivering and administering sessions and programmes
• Sending session confirmation and practical information
• Improving the content and delivery of our programmes, based on feedback
• Maintaining records of participation where relevant
• Complying with our legal obligations

We do not use personal data for automated decision-making or profiling. We do not sell personal data to third parties.

We may send occasional programme updates or notifications about new sessions if you have given your consent. You may withdraw this consent at any time by contacting us at [email protected].

4. Sharing Personal Data

We do not sell, rent or trade personal data. We may share data with:

• Service providers: third-party companies that assist us in operating our website or delivering communications (for example, email delivery services), under appropriate data processing agreements
• Legal authorities: if required by applicable Thai law or a valid legal process

Any third-party service providers we engage are required to handle personal data in a manner consistent with this policy and applicable data protection law.

5. Data Protection Measures

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. These measures include:

• Encrypted data transmission (HTTPS) for our website
• Access controls limiting who within our small team can view personal data
• Secure storage of physical documents handled during records sessions
• Regular review of access credentials and security practices

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable Thai data protection law within the timeframes required by law.

6. Cookies

Our website uses cookies to enable basic functionality and, where you have given consent, to analyse how the site is used. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

Essential cookies are necessary for the website to function and are placed without consent. All other cookies are only placed with your consent, which you can give or withdraw using the cookie preference controls on our site.

7. Your Rights

Under Thailand's Personal Data Protection Act B.E. 2562 (PDPA) and, where applicable, other data protection law, you have the following rights in relation to your personal data:

• Right to 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 personal data in certain circumstances
• Right to restrict processing: to request that we limit how we use your data
• Right to data portability: to receive your data in a structured, machine-readable format where technically feasible
• Right to object: to object to processing based on legitimate interests
• 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 [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with Thailand's Personal Data Protection Committee or another relevant supervisory authority.

8. Third-Party Links

Our website may contain links to external websites for reference or convenience. We are not responsible for the privacy practices or content of those sites and this policy does not apply to them. We encourage you to read the privacy notices on any external sites you visit.

9. Children's Privacy

Our services are intended for adults aged 18 or over. We do not knowingly collect personal data from children under the age of 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, the "Last Updated" date at the top of this page will change. We will take reasonable steps to bring material changes to your attention, for example by placing a notice on our website.

Continued use of our website or services after any update constitutes acceptance of the revised policy.