Privacy Policy

1. Who we are

Embark Estate Co., Ltd. (“Embark Estate”, “we”, “us”) is a boutique real estate advisory based in Bangkok, Thailand. For the personal data described in this policy, we are the data controller, the party that decides why and how your data is used.

• Company: Embark Estate Co., Ltd. [company registration number to confirm]
• Office: One Bangkok, Tower 4, 28th Floor, Wireless Road, Pathum Wan, Bangkok 10330, Thailand [registered office address to confirm]
• Email: contact@embarkestate.com
• Data protection contact: contact@embarkestate.com [dedicated privacy address or Data Protection Officer to confirm]

2. The scope of this policy

This policy covers the personal data we collect when you visit embarkestate.com, use our enquiry or newsletter forms, contact us by email or messaging app, or otherwise engage us as an advisory. It does not cover third-party websites we link to, which have their own policies.

3. The personal data we collect

We collect only what we need to advise you well. In practice that means:

Information you give us

• Enquiry details: your name, email address, telephone number, messaging-app handles (WhatsApp, LINE, WeChat) where you choose to share them, the corridors or projects you are interested in, your budget range, and the content of your message, submitted through our contact form, by email, or by messaging app.
• Newsletter sign-up: your email address, and the frequency you choose, when you subscribe to the Embark Quarterly.
• Correspondence: records of our communications with you, including notes relevant to advising on a purchase or rental.

Information collected automatically

• Technical and usage data: your device type, browser, approximate location derived from your IP address, the pages you view, and how you arrived at the site. This is collected through cookies and similar technologies, subject to your consent where required. See our Cookie Policy.
• Bot-protection signals: our forms use Cloudflare Turnstile, an invisible bot-protection service, which assesses signals such as your browser characteristics to confirm you are human. Turnstile does not use tracking cookies and does not identify you as an individual.

Information from other sources

• Occasionally, information from a referrer who introduces you to us, or from publicly available sources, where relevant to a potential transaction.

We do not seek sensitive personal data (such as health, religion, or biometric data). Please do not send it to us unless we specifically ask and explain why.

4. How we use your data, and our lawful basis

Under the PDPA and the GDPR we must have a lawful basis for each use of your data. Ours are as follows.

• Responding to your enquiry and advising you. To answer your questions, arrange viewings, and guide a purchase or rental. Basis: taking steps at your request before entering a contract, and our legitimate interest in running an advisory business. For some messaging channels, your consent.
• Sending the newsletter. To send the Embark Quarterly and related updates you have asked for. Basis: your consent, which you can withdraw at any time.
• Improving and securing the website. To understand how the site is used, fix problems, and keep it secure. Basis: your consent for analytics cookies, and our legitimate interest in a safe, working site.
• Meeting legal obligations. To comply with applicable law, including tax, accounting, anti-money-laundering, and record-keeping requirements. Basis: compliance with a legal obligation.
• Protecting our rights. To establish, exercise, or defend legal claims. Basis: our legitimate interest, and compliance with a legal obligation.

Where we rely on consent, you are free to refuse or withdraw it without affecting the advisory service you receive, other than the part that depends on that consent (for example, the newsletter).

5. Marketing and the newsletter

We send marketing communications, including the Embark Quarterly, only where you have asked to receive them. Every email includes an unsubscribe link, and you can opt out at any time by using it or by writing to us. We do not sell your data or share it with third parties for their own marketing.

6. Cookies

We use cookies and similar technologies, and ask for your consent to non-essential ones through our cookie banner. You can change your choices at any time. The detail is in our Cookie Policy.

7. Who we share your data with

We share personal data only where necessary, and never sell it. Recipients may include:

• Service providers (processors) who help us run the business under our instructions. Current providers are: Resend for transactional email (your inquiry acknowledgement and our internal records), Brevo for the Embark Quarterly newsletter, Supabase for client-record management and for our own first-party website analytics, Twilio for WhatsApp Business notifications to Embark when you submit an inquiry, and Cloudflare Turnstile for invisible bot protection on our forms, and Microsoft Clarity for privacy-conscious website analytics, used only with your consent. Hosting, and the page-speed measurement built into it, are provided by Vercel.
• Professional advisers, such as independent lawyers, accountants, and auditors, where relevant and appropriate.
• Developers or partners connected to a specific property, only with your knowledge where it is needed to progress your enquiry.
• Authorities and regulators, where we are required to disclose data by law or to protect legal rights.

We require our service providers to protect your data and to use it only for the purposes we specify.

8. International data transfers

Some of our service providers operate outside Thailand, including in the European Economic Area, the United Kingdom, and the United States. Where your data is transferred across borders, we take steps to ensure it remains protected, using recognised safeguards such as standard contractual clauses or transfers to countries with an adequate level of protection, as required by the PDPA and the GDPR. [Specific transfer mechanisms to confirm with counsel once providers are finalised.]

9. How long we keep your data

We keep personal data only as long as we need it for the purposes above, or as the law requires.

• Active enquiries: for the duration of our discussions and a reasonable period afterwards in case you return, and no longer than 24 months after our last contact.
• Newsletter: until you unsubscribe.
• Transaction and accounting records: for the period required by Thai tax and accounting law. [Statutory retention period to confirm.]

When data is no longer needed, we securely delete or anonymise it.

10. How we protect your data

We use appropriate technical and organisational measures to keep personal data secure, including encrypted connections, access controls, and limiting access to those who need it. No system is perfectly secure, but we take reasonable steps to protect your information and to respond promptly if a data breach occurs, in line with our legal obligations.

11. Your rights

Under the PDPA, and the GDPR where it applies to you, you have rights over your personal data. These include the right to:

• be informed about how we use your data (this policy);
• access a copy of the data we hold about you;
• have inaccurate data corrected;
• have your data deleted in certain circumstances;
• restrict or object to certain uses of your data;
• receive your data in a portable format, or have it transferred;
• withdraw consent at any time, where we rely on consent;
• lodge a complaint with a supervisory authority.

To exercise any of these, write to contact@embarkestate.com. We respond within the timeframes set by law. If you are not satisfied, you may complain to Thailand’s Personal Data Protection Committee (PDPC), or, if you are in the EEA or the UK, to your local data protection authority.

12. Children

Our website and services are intended for adults. We do not knowingly collect data from minors. Where a person is a minor under Thai law, parental or guardian consent is required, in line with the PDPA. If you believe a minor has provided us data, please contact us and we will delete it.

13. Changes to this policy

We may update this policy from time to time. The current version, and its effective date, will always appear on this page. Where changes are significant, we will take reasonable steps to bring them to your attention.

14. Contact and complaints

For any question about this policy or your data, write to contact@embarkestate.com or to our office address above. You also have the right to complain to the relevant data protection authority, as set out in section 11.