Smart Living TH

Privacy Policy – Smart Living TH

Privacy Policy

Effective Date: 1 January 2025  |  Last Updated: 1 January 2025

This Privacy Policy describes how Smart Living TH (legal entity: SAAD CONSTRUCTION II CO), operating the website tomorrowthailandapp.net (the “Website”), collects, uses, discloses, and protects the personal data of individuals who visit or interact with our Website. We are committed to safeguarding your privacy in accordance with the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) of Thailand and all applicable subordinate regulations and notifications issued thereunder.

Please read this Privacy Policy carefully. By accessing or using our Website, submitting any contact form, or otherwise interacting with our services, you acknowledge that you have read, understood, and agree to the practices described herein. If you do not agree with this Privacy Policy, please discontinue use of the Website immediately.

1. Introduction and Identity of the Data Controller

Smart Living TH (registered under the legal name SAAD CONSTRUCTION II CO) acts as the Data Controller as defined under Section 6 of the PDPA. This means we determine the purposes and means of processing your personal data.

Our contact details are as follows:

  • Company Name: Smart Living TH (SAAD CONSTRUCTION II CO)
  • Website: tomorrowthailandapp.net
  • Email: [email protected]
  • Phone: +12314844485
  • Address: 18191 NW 68TH Ave Ste 104, Hialeah, Florida, 33015-3997, United States

For any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, you may contact us at the details above or via the dedicated privacy inquiry contact described in Section 14 of this Policy.

2. Scope of This Privacy Policy

This Privacy Policy applies to all personal data collected through:

  • The Website at tomorrowthailandapp.net and any sub-pages thereof;
  • Contact forms and inquiry submissions made through the Website;
  • Cookies and similar tracking technologies placed on your device when you browse the Website;
  • Any correspondence, calls, or emails you initiate with us.

This Policy does not apply to third-party websites, applications, or services that may be linked from our Website. We encourage you to review the privacy policies of any third-party platforms you visit independently.

3. Personal Data We Collect

We collect personal data only to the extent necessary for the purposes described in this Policy. The categories of personal data we collect include:

3.1 Data Provided Directly by You (Contact Form Submissions)

When you complete and submit a contact or inquiry form on our Website, we collect the following information:

  • Full Name: To identify and address you in our correspondence;
  • Email Address: To respond to your inquiry and send relevant communications;
  • Phone Number: To contact you by telephone if required to address your inquiry;
  • Message / Inquiry Content: The details of your request, question, or feedback as submitted in the message field of the form.

Providing this information is voluntary; however, failure to provide the required fields may prevent us from responding to your inquiry effectively.

3.2 Data Collected Automatically (Technical and Usage Data)

When you visit our Website, certain technical data is automatically collected by our web servers and/or analytics tools, including but not limited to:

  • IP Address and approximate geographic location derived therefrom;
  • Browser type and version;
  • Operating system and device type;
  • Pages visited and navigation paths within the Website;
  • Date and time of your visit;
  • Referring URL (the website from which you arrived);
  • Session duration and interaction events.

This data is collected through server logs and, where enabled, through cookies or analytics scripts as described in Section 5 below.

3.3 Sensitive Personal Data

We do not intentionally collect any sensitive personal data as defined under Section 26 of the PDPA, including racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual behaviour, criminal records, health data, disability information, trade union membership, genetic data, or biometric data. Please do not submit such information through any form or communication channel on our Website.

4. Legal Basis for Processing and Purposes of Processing

Under the PDPA, we must have a lawful basis for processing your personal data. We rely on the following legal bases:

  • Contractual Necessity (Section 24(3) PDPA): Where processing is necessary to take steps at your request prior to entering into a contract, or to perform a contract to which you are a party — for example, responding to a service inquiry.
  • Legitimate Interests (Section 24(5) PDPA): Where processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms — for example, ensuring Website security, preventing fraud, and improving our services through analytics.
  • Consent (Section 19 PDPA): Where you have freely given, specific, informed, and unambiguous consent — for example, consenting to optional analytics cookies. You may withdraw consent at any time without detriment.
  • Legal Obligation (Section 24(1) PDPA): Where processing is necessary to comply with a legal obligation applicable to us under Thai law.

The purposes for which we process your personal data include:

  • Responding to contact form submissions and general inquiries;
  • Providing information about our services or products;
  • Managing and maintaining our Website and ensuring its technical functionality;
  • Conducting internal analytics and improving Website user experience;
  • Complying with applicable legal obligations, regulatory requirements, and dispute resolution;
  • Protecting the security and integrity of our systems.

5. Cookies and Similar Tracking Technologies

Our Website uses cookies — small text files placed on your device — and similar technologies to enhance your browsing experience, analyse usage patterns, and support Website functionality. In accordance with the PDPA and applicable guidelines, we categorise our cookies as follows:

5.1 Strictly Necessary / Functional Cookies

These cookies are essential for the Website to function correctly. They enable core features such as page navigation, security, and session management. Because they are strictly necessary, they do not require your consent and cannot be disabled without impairing Website functionality.

Examples include:

  • Session management cookies that keep you logged in during a session;
  • Security tokens that protect against cross-site request forgery (CSRF);
  • Load-balancing cookies that ensure stable server performance.

5.2 Optional Analytics Cookies

With your prior consent, we may use analytics cookies to collect aggregated and anonymised information about how visitors use the Website. This helps us understand which pages are most visited, how users navigate the site, and where improvements can be made. These cookies do not identify you personally.

We may use third-party analytics platforms such as Google Analytics for this purpose. Data collected through analytics cookies may be processed on servers outside Thailand (see Section 11 on international transfers).

You may withdraw consent to analytics cookies at any time by adjusting your browser settings or using our cookie preference tool, if provided.

5.3 How to Manage Cookies

You can control and manage cookies through your web browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling certain cookies may affect the functionality and performance of the Website. For more information on managing cookies, visit www.allaboutcookies.org.

6. Third-Party Services and External Resources

Our Website may utilise third-party services and resources to deliver content and functionality. These services may independently collect data about your interactions. The third-party services currently used or potentially used by this Website include:

  • Google Fonts (Google LLC): We may load fonts from Google Fonts servers to ensure consistent and aesthetically appropriate typography. When fonts are requested, your IP address and browser information may be transmitted to Google's servers in the United States. Google's Privacy Policy governs such data: policies.google.com/privacy.
  • Tailwind CSS CDN: We may load Tailwind CSS from a content delivery network (CDN) to style our Website. Loading resources from a CDN may result in your IP address being transmitted to CDN server operators. These requests are technical in nature and do not typically involve the processing of personal data beyond the IP address for connection purposes.
  • Google Analytics (optional): If enabled, Google Analytics may collect anonymised usage statistics. Please refer to Google's Privacy Policy and opt-out tools for more information.
  • Email / Form Processing Infrastructure: Contact form submissions may be transmitted via server-side processing (PHP mailer or equivalent) and potentially via third-party SMTP services to deliver your inquiry to our team. Data is handled securely and not retained by intermediary services beyond transmission.

We are not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third party whose services are integrated into or linked from our Website.

7. How Contact Form Submissions Are Processed

When you submit a contact form on our Website, the following processing steps occur:

  1. Your submission (name, email, phone, and message) is received by our web server at tomorrowthailandapp.net;
  2. The data is processed server-side and transmitted securely via email to our designated staff inbox;
  3. Our team reviews your inquiry and prepares a response, typically within 2–5 business days (Thai working days, Monday to Friday, excluding public holidays);
  4. Your data is stored in our email system and/or CRM for the duration necessary to manage your inquiry and maintain our records;
  5. Your submission data is not sold, rented, or shared with unaffiliated third parties for marketing purposes without your explicit consent.

We implement server-side validation and HTTPS encryption to protect data in transit from your browser to our servers.

8. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, as outlined in this Policy, or as required by applicable Thai law.

  • Contact Form Submissions: Retained for a period of three (3) years from the date of submission, unless a longer retention period is required to resolve a dispute, comply with a legal obligation, or fulfil a contractual obligation.
  • Technical / Server Log Data: Retained for up to twelve (12) months for security and operational purposes, after which it is automatically deleted or anonymised.
  • Analytics Data (if applicable): Retained in accordance with the data retention settings configured within the analytics platform (typically 14 months for Google Analytics), after which data is automatically deleted.
  • Cookies: Session cookies expire when you close your browser. Persistent cookies expire according to the duration set at the time of placement, as detailed in our cookie settings.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed, or anonymised in accordance with our internal data retention procedures.

9. Data Security Measures

We take the security of your personal data seriously and implement appropriate technical and organisational security measures to protect your data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

  • SSL/TLS Encryption: All data transmitted between your browser and our Website is encrypted using Secure Sockets Layer (SSL) / Transport Layer Security (TLS) protocols (HTTPS);
  • Access Controls: Access to personal data is restricted to authorised personnel who require such access to perform their job functions, on a strict need-to-know basis;
  • Secure Email Handling: Form submission data transmitted by email is handled through secure, authenticated email channels;
  • Regular Security Reviews: We periodically review our information security practices and update them as appropriate to address new threats;
  • Software Updates: We maintain up-to-date server software, plugins, and security patches to minimise vulnerabilities;
  • Firewalls and Intrusion Detection: Our hosting environment employs firewall protections and monitoring to detect and respond to unauthorised access attempts.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Office of the Personal Data Protection Committee (PDPC) within 72 hours of becoming aware of the breach, and notify affected individuals without undue delay, as required under Section 37 of the PDPA.

10. Your Rights Under the PDPA and How to Exercise Them

Under the Personal Data Protection Act B.E. 2562 (2019), you have the following rights with respect to your personal data that we hold:

  1. Right to be Informed (Section 23): You have the right to be informed at the time of collection about the purposes of processing, the types of data collected, and how long it will be retained. This Privacy Policy fulfils that obligation.
  2. Right of Access (Section 30): You have the right to request confirmation of whether we hold your personal data and to obtain a copy of such data, along with information about how it is being processed.
  3. Right to Rectification (Section 35): You have the right to request that inaccurate, incomplete, or misleading personal data be corrected or updated without undue delay.
  4. Right to Erasure / Right to be Forgotten (Section 33): You have the right to request the deletion or destruction of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where the data has been unlawfully processed, subject to any overriding legal obligations we may have to retain it.
  5. Right to Restrict Processing (Section 34): You have the right to request that we suspend the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
  6. Right to Data Portability (Section 31): Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller where technically feasible.
  7. Right to Object (Section 32): You have the right to object to the processing of your personal data where processing is based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will cease such processing immediately.
  8. Right to Withdraw Consent (Section 19): Where processing is based on your consent, you may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
  9. Right to Lodge a Complaint (Section 73): You have the right to lodge a complaint with the Personal Data Protection Committee (PDPC) if you believe that our processing of your personal data violates the PDPA. Contact information for the PDPC is available at www.pdpc.or.th.

To exercise any of the above rights, please submit a written request to us using the contact details provided in Section 14. We will respond to your request within 30 days of receipt, as required by the PDPA. In complex cases, we may extend this period by a further 30 days and will notify you accordingly. We may need to verify your identity before processing your request.

We will not charge a fee for processing data rights requests unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee.

11. International Transfers of Personal Data

As a company operating in Thailand, we primarily process and store your personal data within Thailand. However, certain third-party services we use — such as Google Fonts, Google Analytics, and CDN providers — may result in your data being transferred to and processed in countries outside Thailand, including the United States and countries within the European Union.

Where personal data is transferred internationally, we ensure that such transfers are conducted in accordance with Chapter 7 of the PDPA (Sections 28–29), which requires that the destination country must have adequate data protection standards as determined by the PDPC, or that appropriate safeguards are in place, such as:

  • Standard Contractual Clauses (SCCs) approved by the PDPC;
  • Binding Corporate Rules;
  • Your explicit consent to the transfer after being informed of the risks;
  • The transfer being necessary for the performance of a contract at your request.

For transfers to Google's servers, Google LLC has self-certified under applicable data transfer frameworks and provides contractual protections through its terms of service and Data Processing Agreements. We rely on these mechanisms to legitimise cross-border transfers where they occur.

12. Children's Privacy

Our Website and services are not directed to, and we do not knowingly collect personal data from, children under the age of 20 years (the age of majority under Thai civil law) or minors under the age of 10 years as referenced in the PDPA's provisions on consent by minors.

In accordance with Section 20 of the PDPA, if a minor (person under 20 years of age who is not emancipated) wishes to submit a contact form or otherwise provide personal data through our Website, the consent of a parent or legal guardian is required. We do not have mechanisms in place to independently verify the age of users, and it is therefore the responsibility of parents and guardians to supervise their children's online activities.

If we become aware that we have inadvertently collected personal data from a child under 10 years of age without the requisite parental consent, we will take prompt steps to delete such data from our records. If you believe we may have collected data from a child without appropriate consent, please contact us immediately at [email protected].

13. Disclosure of Personal Data to Third Parties

We respect the confidentiality of your personal data. We do not sell, trade, or rent your personal data to third parties for their own marketing purposes. We may share your personal data in the following limited circumstances:

  • Service Providers: We may share data with trusted third-party service providers who assist us in operating the Website, processing form submissions, or delivering services (e.g., hosting providers, email delivery services). These providers are contractually bound to process your data only in accordance with our instructions and applicable law;
  • Legal Compliance: We may disclose your personal data to government authorities, regulators, law enforcement agencies, or courts where required to do so by applicable Thai law, a court order, or regulatory directive;
  • Protection of Rights: We may disclose your data where necessary to protect the rights, property, or safety of Smart Living TH, our clients, or the public, as permitted under the PDPA;
  • Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity, subject to equivalent data protection commitments. We will notify you of any such transfer where required by law;
  • With Your Consent: We may share your data with third parties where you have given us specific, informed, and freely given consent to do so.

14. Privacy Inquiries and Contact Information

If you have any questions, concerns, or complaints about this Privacy Policy, our data processing practices, or if you wish to exercise any of your rights under the PDPA, please contact our designated privacy point of contact:

  • Company: Smart Living TH (SAAD CONSTRUCTION II CO)
  • Email: [email protected]
  • Phone: +12314844485
  • Postal Address: 18191 NW 68TH Ave Ste 104, Hialeah, Florida, 33015-3997, United States

We are committed to addressing your concerns promptly and in good faith. We aim to respond to all privacy-related enquiries within 30 days of receipt. Where additional time is needed due to the complexity or volume of requests, we will inform you of the delay and the expected response timeline.

If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Personal Data Protection Committee (PDPC), which is the supervisory authority for data protection in Thailand:

15. Changes to This Privacy Policy

We may update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable law (including amendments to the PDPA or new PDPC notifications and guidelines), or developments in our business operations.

When we make material changes to this Privacy Policy, we will take appropriate steps to notify you, which may include:

  • Posting a prominent notice on our Website homepage or the Privacy Policy page;
  • Sending an email notification to users who have provided their email address, where applicable;
  • Updating the “Last Updated” date at the top of this Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the Website after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms, to the extent permitted by applicable law. Where changes require fresh consent under the PDPA, we will seek such consent before continuing to process your data on the new basis.

All previous versions of this Privacy Policy are available upon written request to [email protected].

16. Thailand Legal Compliance Statement

Smart Living TH (SAAD CONSTRUCTION II CO) is committed to full compliance with the Personal Data Protection Act B.E. 2562 (2019) and all subordinate legislation, notifications, and guidelines issued by the Personal Data Protection Committee (PDPC) of Thailand. Our data processing activities are governed by the following key principles embedded in the PDPA:

  • Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner in relation to the data subject;
  • Purpose Limitation: We collect personal data for specified, explicit, and legitimate purposes and do not process it in a manner incompatible with those purposes;
  • Data Minimisation: We collect only the personal data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
  • Accuracy: We take reasonable steps to ensure that personal data is accurate, kept up to date, and corrected without delay;
  • Storage Limitation: We retain personal data no longer than is necessary for the purposes for which it was collected;
  • Integrity and Confidentiality: We process personal data with appropriate security, protecting against unauthorised or unlawful processing, accidental loss, destruction, or damage;
  • Accountability: We take responsibility for compliance with the above principles and are able to demonstrate that compliance to the PDPC.

This Website operates under Thai jurisdiction. Any disputes arising from this Privacy Policy or our data processing practices shall be governed by the laws of the Kingdom of Thailand and subject to the jurisdiction of Thai courts and the PDPC.

17. Governing Law

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Kingdom of Thailand, including but not limited to the Personal Data Protection Act B.E. 2562 (2019), the Computer Crime Act B.E. 2550 (2007) as amended, and any other applicable Thai legislation. Any disputes or claims arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Thailand.

Effective Date: 1 January 2025  |  Last Updated: 1 January 2025  |  Version: 1.0

This Privacy Policy was prepared by Smart Living TH (SAAD CONSTRUCTION II CO) for the website tomorrowthailandapp.net in compliance with the Personal Data Protection Act B.E. 2562 (2019) of Thailand.