Who we are
Our website address is: https://www.actioconsultancy.com
TYPES OF DATA COLLECTED
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: address; first name; last name; gender; phone number; email address; Cookies; Usage Data; company name; country; various types of Data; field of activity; website.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE, LEGAL BASIS AND PLACE OF PROCESSING THE DATA
METHODS OF PROCESSING
The Owner will not transfer any Personal Data to any third party who does not expressly have the right to receive it under this Policy. Data is not sold or licensed to anyone who is not involved in providing the Website’s services.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
LEGAL BASIS OF PROCESSING
The Owner will process Personal Data relating to Users on one of the following applicable bases:
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner.
In any case, the provision of Personal Data is a contractual requirement necessary to be able to provide products and service to Users.
Other than in relation to Cookies or other tracking tools (for which see below), all Personal Data is processed at the Owner’s operating offices in the Thailand, and all Data from outside the Thailand will be transferred in accordance with all protections required under relevant law, including GDPR. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the Thailand or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
DATA TRANSFER OUTSIDE THE THAILAND
The Owner is allowed to transfer Personal Data collected within the Thailand to the EU as well as other third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Interaction with data collection platforms and other third parties, Analytics, Platform services and hosting, Remarketing and behavioral targeting, Handling payments, Interaction with external social networks and platforms, Interaction with live chat platforms, Contacting the User, Content performance and features testing (A/B testing), Displaying content from external platforms, Social features, Heat mapping and session recording and Data transfer outside the Thailand.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
K DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
HOW TO EXERCISE THESE RIGHTS
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
M ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
N ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA
O SYSTEM LOGS AND MAINTENANCE
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
P INFORMATION NOT CONTAINED IN THIS POLICY
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Q HOW “DO NOT TRACK” REQUESTS ARE HANDLED
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
S DEFINITIONS AND LEGAL REFERENCES
PERSONAL DATA (OR DATA)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
DATA PROCESSOR (OR DATA SUPERVISOR)
DATA CONTROLLER (OR OWNER)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
THIS WEBSITE (OR THIS APPLICATION)
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/application.
EUROPEAN UNION (OR EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
T LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Personal Data Protection Act, B.E. 2562 (2019).
Latest update: 28th May 2021