Privacy Policy

1. Introduction

Witthaya Code ("we", "our", "us"), operating from 248 Nimmanhaemin Road, Suthep, Mueang, Chiang Mai 50200, Thailand, is committed to handling personal data responsibly. This policy explains what data we collect, why we collect it, how we use it, and the rights you hold over your information.

This policy applies to personal data collected through our website at witthaya.live, our contact forms, and any data shared in the course of enrolment in our programmes. If you have questions, contact us at [email protected].

2. Data We Collect

We collect the following categories of personal data:

• Contact information: name, email address, phone number (optional), provided through our contact or enquiry forms.
• Enrolment data: information about your background, experience level, and programme preferences, shared during the enquiry and enrolment process.
• Programme data: submitted exercises, project files, messages exchanged with mentors, and feedback records during active programmes.
• Technical data: IP address, browser type, device information, and pages visited, collected through cookies and server logs.
• Communication records: emails or messages you send us directly.

We do not collect financial data directly. Payment information is handled through third-party processors and is not stored by Witthaya Code.

3. Legal Basis for Processing

We process personal data on the following legal bases under Thailand's Personal Data Protection Act B.E. 2562 (PDPA):

• Consent: for marketing communications and non-essential cookies, where you have given explicit consent.
• Contract performance: for data necessary to deliver a programme you have enrolled in.
• Legitimate interests: for analytics, security, and service improvement, where those interests do not override your rights.
• Legal obligation: where required by Thai law or regulatory authority.

4. How We Use Your Data

• To respond to enquiries and help you select a suitable programme
• To manage your enrolment and deliver programme content
• To provide mentor feedback on your submitted work
• To send programme-related communications (schedule updates, feedback notifications)
• To improve our website and programme materials using aggregated analytics
• To comply with Thai legal and tax obligations

We do not sell personal data to third parties. We do not use your data for automated profiling or algorithmic decision-making that produces legal or similarly significant effects.

5. Data Retention

• Enquiry data (not resulting in enrolment): deleted within 12 months of last contact.
• Enrolment and programme data: retained for 3 years after programme completion, then deleted unless required by law.
• Communication records: retained for 2 years from the date of the last message.
• Technical/cookie data: retained as defined in our Cookie Policy.

6. Third-Party Services

We use the following third-party services which may process your data:

• Google Analytics: anonymised website usage data. You can opt out via cookie preferences.
• Email delivery providers: to send programme-related communications.
• Payment processors: payment data handled by the processor directly; we receive only confirmation of payment.

Each third-party service operates under its own privacy policy. We select providers that offer adequate data protection standards.

7. Data Protection Measures

• Data in transit is encrypted via HTTPS/TLS.
• Access to personal data is restricted to staff who need it to perform their role.
• Passwords and credentials are never stored in plain text.
• We review our data handling practices annually.
• In the event of a data breach affecting your rights, we will notify you within 72 hours of becoming aware, as required by the PDPA.

8. Cookies

Our website uses cookies for essential functions, analytics, and preference storage. Full details of the cookies we use, their purposes, and how to manage your preferences are available in our Cookie Policy.

9. Your Rights

Under Thailand's PDPA, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase data that is no longer necessary for the purpose it was collected
• Restrict processing in certain circumstances
• Data portability — receive your data in a structured, machine-readable format
• Object to processing based on legitimate interests
• Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, email [email protected]. We will respond within 30 days. You may also lodge a complaint with Thailand's Personal Data Protection Committee (PDPC) if you believe your rights have been violated.

10. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies separately.

11. Children's Privacy

Our programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that we have done so, we will delete the data promptly. If you believe a minor has submitted data to us, please contact [email protected].

12. Policy Updates

We may update this policy from time to time. When we do, we will update the "Last updated" date at the top. For material changes, we will notify active programme participants by email. Continued use of our services after any change constitutes acceptance of the revised policy.

13. Contact

Data controller: Witthaya Code
248 Nimmanhaemin Road, Suthep, Mueang, Chiang Mai 50200, Thailand
Email: [email protected]
Phone: +66 53 304 187