Privacy Policy
This privacy policy ("Policy") describes how Cookie Wow ("nDataThoth Co., Ltd", "we","us" or "our") collects, uses and disclose the personally identifiable information ("Personal Information") you ("User", "you" or "your") provide on the Cookie Wow website and any of its products or services (collectively, "Cookie Wow website" or "Services") to be in accordance with Personal Data Protection Act B.E. 2562 (2019) (“PDPA”).
It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Automatic collection of information
When you visit the Cookie Wow website our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Cookie Wow website, pages of Cookie Wow website that you visit, the time spent on those pages, information you search for on Cookie Wow website, access times and dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding Cookie Wow website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
Collection of personal information
You can visit the Cookie Wow website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the Cookie Wow website's features, you will be asked to provide certain Personal Information (for example, your name and email address). We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any online forms on the Cookie Wow website. When required, this information may include the following:
- Identity information such as name, surname, age, date of birth, identification number, passport.
- Contact information such as email address, address, telephone number.
- Account information such as username, unique user ID, password.
- Proof of identity such as copy of identification card, copy of passport.
- Payment information such as credit card details, bank details, transaction history.
- Any information contains in materials you willingly submit to us such as articles, images, motion pictures, feedback and any other information that is considered to be personal data under the PDPA.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the Cookie Wow website's features and Services. Users who are uncertain about what Personal Information is mandatory are welcome to contact us.
Managing Personal Information
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Cookie Wow website or Services change. When you delete your Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Cookie Wow website or simply by contacting us.
Storage of Personal Information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and terms and conditions unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporate your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Your data will be transferred out of Thailand as our infrastructures are located in: Singapore
Use and processing of collected Personal Information
In order to make Cookie Wow website and Services available to you, or to comply with a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of the information we collect is directly from you via Cookie Wow website. However, we may also collect your Personal Information from other available sources including, but not limited to, referral program of nDataThoth Co., Ltd., social media, emails. Any of Personal Information we collect from you may be used for the following purposes:
- Create and manage user account
- Fulfill and manage orders
- Deliver products or services
- Improve products and services
- Send administrative information
- Send marketing and promotional communications
- Respond to inquiries and offer support
- Request user feedback
- Improve user experience
- Post customer testimonials
- Enforce terms and conditions and other policies
- Protect from abuse and malicious users
- Respond to legal requests and prevent harm
- Operate and manage Cookie Wow Website and Services
- Participate in any other activities related to Cookie Wow Website and Services
Processing your Personal Information depends on how you interact with Cookie Wow website, where you are located in the world and if one of the following applies: (i) You have given your consent for one or more specific purposes. This, however, does not apply, whenever the processing of Personal Information is subject to PDPA (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof (iii) Processing is necessary for compliance with a legal obligation to which you are subject (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some circumstance we may be allowed to process your Personal Information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
We never sell your data to another party; we are using these Services of the following external data processors:
- Amazon Web Services (Infrastructure and web hosting services/email) [Singapore/Japan]
- Slack [United States of America]
- Crisp [United States of America]
- Howuku [United States of America]
- Pipedrive [United States of America]
- Google Workspace [United States of America/Singapore/Worldwide]
- Google Analytics [United States of America/Singapore/Worldwide]
- Stripe [United States of America/Japan]
- Facebook Pixel [United States of America]
- SurveySensum [United States of America]
- ConvertBox [United States of America]
- PDPA Form [Singapore/Thailand]
Information transfer and storage
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.
Your user data is safely stored in Singapore. The Cookie Wow core infrastructure is hosted in Singapore. We are complying with Thailand Personal Data Protection Act 2019 and offer all the rights requested by the laws.
Even though we are hosting some Personal Information outside Thailand, we are following proper data protection and selected a Data Center that has higher standards for both security and availability. As we cannot find any data center in Thailand that meets the standards, so we are required to host our core infrastructure in Singapore and Japan as a disaster recovery site while some of the Personal Information used for billing is stored and processed in Thailand.
The rights of User
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information. However, the withdrawal of consent shall not affect the collection, use or disclosure of Personal Information you have already given consent legally (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof and (viii) You have the right to lodge a complain to the competent authorities pursuant to relevant laws if you believe that the collection, use or disclosure of your Personal Information by us is violating or not in compliance with relevant laws.
How to exercise these rights
Any requests to exercise User rights can be directed to the owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the owner as early as possible.
Online form is available at: https://ndatathoth.pdpaform.com (Please mention in the form that the request is for Cookie Wow website)
Billing and payments
We use third-party payment processors to assist us in processing your payment information securely. Such third-party processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
Product and service providers
We may contract with other companies to provide certain products and services. These service providers are not authorized to use or disclose your Personal Information except as necessary to perform services on our behalf or comply with legal requirements. We may share Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 20. If you are under the age of 20, please do not submit any Personal Information through Cookie Wow website or Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through Cookie Wow website or Services without their permission.
If you have reason to believe that a child under the age of 20 has provided Personal Information to us through our Cookie Wow website or Service, please contact us. You must also be at least 20 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).
Do we use web beacons or tracking pixels?
Our emails may contain a "web beacon" (or "tracking pixel") to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email.
We may use this information for purposes including determining which of our emails are more interesting to users and to query whether users who do not open our emails wish to continue receiving them.
The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should read the email in plain text view or with images disabled.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Cookie Wow website does not track its visitors over time and across third party websites. However, some third-party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Links to other websites
Cookie Wow website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Website and to read the privacy policies of each and every website that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
nDataThoth is certified with ISO27001:2013
Data breach
In the event we become aware that the security of the Cookie Wow website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities within 72 hours after having become aware of it. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on Cookie Wow website or send you an email.
Legal disclosure
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.
Changes and amendments
We may update this Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When changes are made, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website or Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different from what was stated at the time your Personal Information was collected.
Contacting us
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form or send an email to dpo@ndatathoth.com or write a letter to nDataThoth Co., Ltd., 7 Summer Point, 2nd Fl. Soi Sukhumvit 69, Phra Khanong Nua, Wattana, Bangkok 10110 Thailand.
Social media cookies
Third-party cookies from social media sites (such as Facebook, Twitter, etc) let us track social network users when they visit our Website, use our Services or share content, by using a tagging mechanism provided by those social networks.
These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ privacy policies. We will not collect or share any personally identifiable information from the user.