Privacy Policy

Privacy Policy

Effective Date: May 19, 2026

1 – Introduction Welcome to Asbe Invest, which is operated and managed by Elata Co., Ltd. ("we", "us", or "our"). We respect the privacy and confidentiality of the personal data of our clients, employees, associates, and others whom we interact with in the course of providing our training courses and services. We are committed to implementing policies, practices, and processes to safeguard the collection, use, and disclosure of the personal data you provide us, in compliance with the Personal Data Protection Act, B.E. 2562 (2019) (PDPA) of Thailand.

We have developed this Privacy Policy to assist you in understanding how Asbe Invest (managed by Elata Co., Ltd.) collects, uses, discloses, processes, protects, and retains your personal data that is in our possession.

2 – How We Collect Your Personal Data Personal data refers to any information relating to a person, which enables the identification of such person, whether directly or indirectly, but not including the information of the deceased persons in particular.

We collect your personal data in the following scenarios and channels:

• Human Resources (HR):
• • When you apply for job positions through our recruitment process, whether as an employee, volunteer, or contractor.
  • When you express interest or participate in our organizational internal activities through sign-up forms or digital platforms.
  • When you engage in employee or HR-related activities, such as submitting medical or insurance claims, leave requests, or other employment-related forms.
  • Through employer-provided or authorized sources, such as when your details are provided for group insurance, training, or other employee benefits.
• Sales:
• • Upon purchasing goods, courses, or services from us, both through our online platforms and during in-person office visits, including your participation in loyalty programs.
  • When you make payments, including via credit card, debit card, bank transfer, or other payment methods.
  • When you request information, quotes, or customer service through our website’s contact forms or digital tools (e.g., chatbots).
  • When you make inquiries about our products or services through website forms, emails, or customer support channels.
  • When you submit claims or requests under any insurance, product warranties, or guarantees.
  • When you participate in contests, lucky draws, or competitions hosted by us or in partnership with other brands.
  • When you respond to promotional offers, either online or in-store, including providing your details for coupons, discounts, or exclusive offers.
• Marketing:
• • During the registration process for any events, training courses, or programs conducted by us, including any online sign-ups or applications.
  • When you subscribe to our newsletters, marketing materials, or promotional emails via EDMs (Electronic Direct Mail) or through a third-party EDM service provider.
  • When you participate in our surveys, polls, or research activities, including any feedback or testimonials you provide.
  • When you interact with us through social media platforms, by following our pages, liking our posts, or engaging in direct messages (DMs).
  • Through referral programs, where a third party refers your contact details to us lawfully.
  • When you register for any loyalty or membership programs to track your preferences, purchases, or loyalty points.
  • When we receive your data through public platforms, directories, or social media aggregators in accordance with legal permissions.
  • When you request to be placed on our mailing lists for any type of notification or communication.
  • When you engage with our affiliates or partners who pass on your details for collaborative purposes, such as joint marketing efforts or shared services.
• IT & Data Security:
• • When you visit our websites or interact with us through social media platforms or online forums.
  • When you connect to our public or private Wi-Fi networks within our premises through the use of your device's network information.
  • Through surveillance and security systems, such as CCTV monitoring within our office premises or event locations.
  • When you use our mobile apps or digital services and provide registration and ongoing data such as location, device information, or usage statistics.
• Legal & Compliance:
• • During the submission of corporate documents, personal information provided in the process of KYC (Know Your Customer) compliance, due diligence, or regulatory reporting.
  • From trusted third-party sources, such as credit reporting agencies, market research organizations, or government agencies.
  • When you submit personal data as part of compliance with legal obligations (e.g., for tax purposes, statutory reporting, or regulatory filings).
  • When you submit documents required for legal or regulatory purposes (e.g., copies of identification documents, contracts, or financial information).
• Customer Support:
• • When you provide information to us through customer service or support requests via email, phone, chat, or other communication channels.
• Administration & Operations:
• • Through collaboration or partnerships, where your information is shared with us as part of joint ventures or business alliances, and CCTV systems at office entrances.

3 – Types of Personal Data We Collect About You The types of personal data we collect about you include the following:

• Employment and HR-Related Activities: Full Name, National ID Card Number/Passport Number (Full or last four characters), Date of Birth, Nationality, Gender, Home Address, Personal Email Address, Phone Number (Mobile, Home), Emergency Contact Information, Marital Status, Number of Dependents, Employment History, Salary Information, Bank Account Details (for salary disbursement), Tax records and withholding tax details, Professional Qualifications and Certifications, Performance Reviews and Feedback, Medical or Health Insurance Information, Medical Leave and Absence Records, Disciplinary Records, Background Check Information, Criminal Record (if applicable and legally permitted), Work-Related Travel Data (e.g., passport information, travel history).
• Provision and Usage of Our Products and Services: Full Name, Personal Email Address, Phone Number (Mobile, Work, Home), Billing Address, Shipping Address, Date of Birth, Payment Information (e.g., credit card, debit card, bank details), Transaction History and course purchases, Loyalty Program Membership Details, Customer Service Requests and Correspondence, Surveys and Feedback Responses, Location Data (via online interactions or app usage), IP Address (for fraud prevention or security), Cookies and Website Tracking Data, Device Information (e.g., type of device, operating system), Membership or Subscription Information.
• Visitor and Communication Management: Full Name, CCTV Footage (on-site surveillance within office premises), Wi-Fi Network Information (device name, MAC address, IP address).

4 – How We Use Your Personal Data (Purposes of Processing) We process your personal data under lawful processing bases specified in the PDPA (such as Contractual Basis, Legitimate Interests, Legal Obligation, or Consent) for the following purposes:

• Service Delivery and Management (Contractual Basis): Enrolling you in training programs, courses, and workshops of Asbe Invest that you have registered for; providing consultancy and advisory services; executing transactions and managing accounts, including processing payments, billing, subscriptions, and handling account receivables; fulfilling orders and delivering products or services; administering loyalty programs and benefits; providing customer support, handling inquiries, complaints, and feedback; managing contracts and agreements between you and our organization.
• Business Operations and Development (Legitimate Interests): Conducting market research and analysis to improve our products or services; analyzing website visits and digital engagement to optimize user experience; carrying out surveys and collecting feedback for business improvements; performing internal audits, data analysis, and system research to enhance our offerings.
• Marketing and Communications (Consent / Legitimate Interests): Sending marketing communications and promotional offers via emails, newsletters, or direct mail; conducting direct marketing and lead generation activities, including analyzing the effectiveness of our advertising campaigns; organizing promotional events such as webinars, live demos, and industry conferences; joint marketing initiatives with partner companies.
• Compliance and Legal Obligations (Legal Obligation Basis): Ensuring compliance with legal, regulatory, and fiscal obligations under Thai laws (e.g., the Revenue Code, Accounting Act); supporting law enforcement bodies or regulatory authorities (such as the Office of the Personal Data Protection Commission (PDPC), the Revenue Department); implementing and maintaining security measures, including monitoring to protect against fraud; handling legal disputes and resolving claims or controversies.
• Safety and Security (Legitimate Interests): Ensuring the physical security of our premises, which includes the use of CCTV surveillance and visitor logs; protecting our digital platforms and services against unauthorized access or cyberattacks.
• Human Resources and Employment (Contract / Legal Obligation Basis): Managing employment-related services such as payroll processing, tax withholding, social security contributions, administering employee benefits, and managing employee performance and training mechanisms.

5 – Who We Disclose Your Personal Data To We may disclose some of the personal data you provide us to the following entities or organizations only as necessary to fulfill the purposes stated in this policy:

• Service Providers and Contractors: External Professional Service Providers (e.g., accountants, auditors, bookkeepers, tax advisors); Law Firms or Legal Advisors (for legal advice or dispute resolution); Marketing and Advertising Agencies; Event Organizers (for conferences, seminars, or webinars).
• IT, Data, and Communication Services: Cloud Service Providers (e.g., Dropbox, Microsoft SharePoint, Google Drive); Email Service Providers and EDM Vendors (e.g., Mailchimp, Constant Contact, ActiveCampaign); Data Backup and Recovery Services; IT Infrastructure Providers and web hosting companies.
• Educational and Training Institutions: Accreditation Bodies, Educational Regulators, or training and certification partners (e.g., external trainers, certification bodies).
• Financial Institutions and Payment Processors: Banks and Financial Institutions; Payment Gateway Providers (e.g., PayPal, Stripe).
• Government Agencies and Regulators in Thailand: Law Enforcement Agencies; Office of the Personal Data Protection Commission (PDPC); the Revenue Department; Social Security Office; Department of Business Development, or other statutory boards as required by law.
• Health and Insurance Providers: Health and Medical Service Providersคู่สัญญา (for employee health assessments); Life/Health Insurance Companies for employee benefits administration.
• Recruitment and Third-Party Software: Recruitment Agencies (Headhunters); Background Screening Providers; Customer Relationship Management (CRM) Systems (e.g., Salesforce, HubSpot) and Learning Management Systems (LMS).

6 – How We Manage the Collection, Use, and Disclosure of Personal Data

6.1 Obtaining Consent Before or at the time of collecting, using, or disclosing your personal data, we will notify you of the purposes and processing details through this policy. Where required by law, we will obtain explicit consent from you in writing or via electronic systems. We will not collect more personal data than is necessary for the stated purposes, and we will seek fresh consent if the original purpose changes.

Under certain circumstances, we may process data based on "deemed consent" or contextual context, such as when you voluntarily apply for a job with us by sending in your resume/CV containing personal information.

6.2 Withdrawal of Consent If you wish to withdraw consent that you previously provided to us, you can do so at any time by giving us reasonable advance notice. We will advise you of the likely consequences of your withdrawal (such as you may no longer receive marketing communications, promotions, or exclusive offers from Asbe Invest). Note that the withdrawal of consent shall not affect the collection, use, or disclosure of personal data that you have already given consent to lawfully prior to the withdrawal.

6.3 Use of Cookies We use "cookies" to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to allow the website to recognize you and keep track of your preferences. Cookies make it convenient for you so that you do not have to retype the same information again when you revisit the website. Most cookies we use are "session cookies", which will be deleted automatically from your hard disk at the end of the session. You may choose to turn off cookies in your web browser settings, but doing so may limit your ability to use some features and functions on our website.

7 – Maintaining Accuracy of Your Personal Data We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading, and kept up-to-date. If you have any ongoing relationship with us, it is important that you update us of any changes to your personal data (such as a change in your address or phone number) to ensure continuous high-quality service.

8 – Protection and Security of Personal Data We have implemented appropriate information security and technical measures (such as SSL/TLS data encryption) to protect the personal data we hold about you against loss, misuse, destruction, unauthorized alteration/modification, access, or disclosure. We have also put in place reasonable organizational measures to maintain confidentiality and restrict data access only to authorized personnel on a "need-to-know" basis, and we ensure that our third-party data processors comply with these standard security measures.

9 – Retention and Disposal of Personal Data We retain your personal data in paper or electronic form for an appropriate period necessary to fulfill the purposes stated in this policy:

• User account information and online learning history on Asbe Invest will be kept for the entire duration that you remain a member and use our services.
• Information related to financial transactions, accounting, and tax compliance will be retained for 10 years in order to comply with Thai legal duties.

Once the retention periods expire, or when the data is no longer necessary under business or legal purposes, we will proceed to delete, destroy, or anonymize the personal data securely in accordance with international standards.

10 – Your Legal Privacy Rights under Thai Law (PDPA Rights) Under the Personal Data Protection Act, B.E. 2562 (2019), you possess legal rights regarding your personal data. You can exercise these rights by contacting us, and we will respond to your request within 30 days from the date we receive your request:

1. Right to Withdraw Consent: You have the right to withdraw your consent for data processing at any time for purposes reliant on consent.
2. Right of Access and to Obtain a Copy: You have the right to request access to and obtain a copy of your personal data under our responsibility, including requesting the disclosure of the acquisition of data obtained without your consent.
3. Right to Rectification: You have the right to request that your personal data be corrected to be accurate, up-to-date, complete, and not misleading.
4. Right to Erasure or Destruction: You have the right to request that we delete, destroy, or anonymize your data when it is no longer necessary or when you withdraw consent.
5. Right to Restrict Processing: You have the right to request the restriction of the use of your personal data temporarily while we verify data accuracy, or when it is no longer needed but you request us to keep it for legal claims.
6. Right to Object: You have the right to object to the collection, use, or disclosure of your personal data at any time (e.g., objecting to direct marketing).
7. Right to Data Portability: You have the right to obtain your personal data in a format that is readable or commonly used by ways of automatic tools, and request to transfer it to other Data Controllers.

11 – Exceptions to Erasure Rights (Educational / Training Context) Please note that, where Asbe Invest (managed by Elata Co., Ltd.) operates as a training provider or educational platform, we may be required by specific laws, regulatory requirements, or directions issued by relevant authorities (such as the Ministry of Education or the Ministry of Labour) to retain certain records (such as learning histories, evaluation results, and certificates). Where retention is required by such specific laws, we will not be able to delete such data until the applicable statutory retention period has expired. We will inform you of the reasons if we are unable to fulfill your deletion request.

12 – Transfer of Personal Data Abroad Where there is a need to transfer your personal data to service providers or servers located outside Thailand (such as international Cloud Storage or CRM platforms), we will ensure that the recipient country maintains a standard of data protection comparable to that of Thailand's PDPA, or enter into contractual agreements ensuring an equivalent level of data protection.

13 – Mandatory Data Breach Notification In the event that we suffer a data breach pertaining to unauthorized access or disclosure of personal data being stored or processed by us, which poses a risk to individual rights and freedoms, we will notify the Office of the Personal Data Protection Commission (PDPC) without delay and within 72 hours from the time we become aware of it. If the breach poses a high risk of significant harm to your rights and freedoms, we will notify you of the breach along with remedial measures as quickly as possible.

14 – Contacting Us If you have any queries, feedback, or wish to exercise your data subject rights under the PDPA law, you can contact us at:

• Brand / Organization Name: Asbe Invest (Operated and managed by Elata Co., Ltd.)
• Website: www.asbeinvest.com
• Email:   [email protected]
• Required Details: Please provide your full name, contact information, and a brief description of your query or the specific right you wish to exercise in your email to facilitate identity verification.

15 – Changes to this Privacy Policy We may update this Privacy Policy from time to time to align with changes in services and legal regulations. The updated version will indicate the "Effective Date" at the very top and will take effect immediately upon being published on this website. Please visit our website periodically to review any updates.