Privacy Policy

1. Introduction

Cobalt Wren ("we", "us", "our") is committed to handling your personal data with care and transparency. This policy explains what information we collect when you use our website or engage with our services, how we use it, and the rights available to you under applicable Thai law — including the Personal Data Protection Act B.E. 2562 (PDPA).

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

2. Data We Collect

Information you provide directly

• Contact form submissions: name, email address, and optionally phone number and message content.
• Service communications: emails, notes, or documents shared with us during an engagement.

Information collected automatically

• Analytics data: page views, session duration, and device type via analytics cookies (if consented to).
• Technical data: IP address and browser type, used only for security and troubleshooting purposes.

Legal basis for processing

• Consent — for optional analytics and marketing cookies.
• Legitimate interest — for website security and internal record-keeping related to advisory engagements.
• Contract performance — for managing service engagements and billing.

Retention periods

Contact form data is retained for up to 24 months. Engagement documentation is retained for up to 5 years. Analytics data is retained in accordance with the third-party analytics provider's standard retention settings (typically 14 months).

3. How We Use Your Data

• To respond to enquiries submitted through our contact form.
• To manage and deliver advisory engagements you have engaged us for.
• To understand how our website is used and improve its content and performance.
• To comply with applicable legal obligations.

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

Marketing communications

We do not send marketing emails unless you have explicitly asked to receive updates from us. You can withdraw consent at any time by contacting us at [email protected].

4. Data Sharing

We may share data with the following categories of third parties, only to the extent necessary:

• Analytics providers (e.g. Google Analytics) — for understanding website usage. Data is processed under standard data processing agreements.
• IT and hosting providers — for maintaining the security and operation of our website.
• Legal or regulatory authorities — if required by Thai law or a valid legal process.

We do not transfer personal data outside Thailand except where required by the services listed above, in which case appropriate safeguards are applied.

5. Data Protection Measures

• Website traffic is encrypted using HTTPS/TLS.
• Access to personal data is restricted to members of the Cobalt Wren team who need it to carry out their work.
• We use reputable, established providers for hosting and analytics.
• In the event of a personal data breach, we will notify affected individuals and the relevant authority within the timeframes required by Thai PDPA.

6. Cookies

We use essential cookies for website functionality and optional analytics and preference cookies. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

7. Your Rights

Under Thai PDPA, you have the following rights regarding your personal data:

• Right to access: request a copy of the personal data we hold about you.
• Right to rectification: request correction of inaccurate data.
• Right to erasure: request deletion of your data where there is no legitimate reason to continue holding it.
• Right to data portability: receive your data in a commonly used, machine-readable format.
• Right to object: object to processing based on legitimate interest.
• Right to withdraw consent: withdraw consent at any time where processing is based on consent.
• Right to lodge a complaint: with the Office of the Personal Data Protection Committee (PDPC) if you believe your rights have been infringed.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

8. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies independently.

9. Children's Privacy

Our services are directed at businesses and are not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If you believe a minor has submitted data through our site, please contact us immediately.

10. Updates to This Policy

We may update this policy from time to time. Changes will be reflected by an updated "Last updated" date at the top of this page. We encourage you to review the policy periodically. Continued use of our website after changes are posted constitutes your acceptance of the revised policy.

11. Contact

Data Controller: Cobalt Wren
19 Huai Kaeo Road, Su Thep, Chiang Mai 50200, Thailand
Email: [email protected]
Phone: +66 53 894 217