Privacy Policy

1. Introduction

Codelumen is committed to handling the personal information of course enquirers, enrolled learners, and website visitors with care and transparency. This policy explains what data we collect, why we collect it, how long we keep it, and what your rights are. It applies to all services we offer via our website and online learning platform.

This policy is written in accordance with Thailand's Personal Data Protection Act B.E. 2562 (PDPA). If you are based in the European Union or European Economic Area, the General Data Protection Regulation (GDPR) may also apply to how we handle your data.

2. Data We Collect

We collect personal data in the following circumstances:

• Contact forms: Name, email address, phone number (optional), and message content.
• Course enrolment: Name, email address, and payment reference (we do not store full card details).
• Website usage: IP address, browser type, pages visited, and time spent — collected via analytics tools if you have consented to analytics cookies.
• Communication: Content of emails or messages you send to us.

3. How We Use Your Data

We use personal data for the following purposes:

• To respond to enquiries submitted through our contact form.
• To process and manage course enrolment and access.
• To deliver course materials, feedback, and support during your enrolment.
• To send administrative communications related to your course (schedule changes, updates).
• To analyse how our website is used and improve its content — only where analytics consent has been given.
• To comply with legal obligations under Thai law.

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

4. Legal Basis for Processing

• Consent: For analytics and marketing cookies, and for optional email updates.
• Contractual necessity: For delivering the courses you have enrolled in.
• Legitimate interests: For responding to contact form enquiries and improving our services.
• Legal compliance: Where processing is required under Thai law or other applicable regulation.

5. Data Retention

• Contact form submissions: retained for 24 months from the date of submission.
• Enrolment and course records: retained for 5 years from the end of the enrolment period for accounting and legal purposes.
• Analytics data: retained as configured in the analytics tool, typically 14 months.

6. Third-Party Services

We use a limited number of third-party services to operate our courses and website:

• Google Analytics: Website usage statistics (only if analytics cookies consented).
• Payment processors: For handling course payment transactions securely.
• Email delivery services: For sending course-related communications.

These service providers process data on our behalf under data processing agreements. They do not use your data for their own purposes.

7. Cookies

We use cookies on our website. Essential cookies are required for basic functionality. Optional analytics and marketing cookies are only used if you give consent via our cookie banner. See our Cookie Policy for full details and preference management.

8. Data Protection Measures

• All data transmitted to and from our website is encrypted via HTTPS/TLS.
• Access to personal data is restricted to staff who need it to carry out their role.
• We review our data security practices regularly.
• In the event of a data breach that affects your rights, we will notify you and the relevant authority within the timeframe required by law.

9. Your Rights

Under the Thailand PDPA and, where applicable, the GDPR, you have the following rights:

• Right to access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can ask us to correct inaccurate or incomplete data.
• Right to erasure: You can request deletion of your personal data where there is no lawful reason to retain it.
• Right to data portability: You can request your data in a structured, machine-readable format.
• Right to object: You can object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to lodge a complaint: In Thailand, you may contact the Personal Data Protection Committee. In the EU, contact your national data protection authority.

To exercise any of these rights, email us at [email protected].

10. Third-Party Links

Our website may contain links to external sites. Codelumen is not responsible for the privacy practices of those sites and encourages you to read their policies separately.

11. Children's Privacy

Our courses and website are intended for individuals aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe a minor has submitted data to us, please contact us and we will remove it promptly.

12. Changes to This Policy

We may update this policy from time to time. When material changes are made, we will notify enrolled learners by email and update the "Last Updated" date at the top of this page. Continued use of our services after changes take effect constitutes acceptance of the updated policy.

13. Contact

For any questions about this policy or to exercise your data rights, contact us at:

• Email: [email protected]
• Address: Codelumen, 112 Rama IX Road, Huai Khwang, Bangkok 10310, Thailand