This Privacy Policy outlines the practices of D-Luck Property Co., Ltd. (referred to as “the Company,” “we,” or “us”) regarding the collection, use, processing, and protection of personal data through its website, www.d-luckproperty.com, and its associated services. We are committed to safeguarding user privacy and adhering to the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) of Thailand. Where applicable due to the targeting of individuals within the European Union, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) may also apply.

1. Information Collected

The Company collects various categories of personal data to provide and improve its real estate services. This information is gathered through direct user input, automatic collection methods, and from third-party sources.

Directly Provided Information

This includes information that users voluntarily provide when interacting with our services: This category includes data voluntarily submitted by users when they interact with the website. Examples include:

• Contact Information: Names, email addresses, phone numbers, and physical addresses, typically provided during property inquiries, registration, or direct communication.
• Account Information: Usernames and passwords, if user accounts are implemented on the platform.
• Inquiry Details: Specific property interests, budget ranges, desired locations, number of bedrooms or bathrooms, and other preferences submitted via contact forms, inquiry forms, or direct messages.
• Feedback and Correspondence: Any information provided when users contact the Company for support, submit feedback, or engage in other forms of communication.

Automatically Collected Information

As users navigate and interact with the website, certain data is collected automatically. This includes:

• Device and Usage Data: Information such as IP addresses, browser types, operating systems, referring URLs, pages viewed, time spent on pages, and clickstream data.
• Location Data: General location derived from IP addresses. Precise geolocation data may also be collected if explicitly enabled by the user’s device settings, which is particularly relevant for property search functionalities.
• Browsing Activity: Details of property search history, properties viewed, saved listings, and any purchase-related activity on the website.
• Analytics Data: Information about user interactions, including clicks, mouse movements, and forms filled out, which is utilized to better understand the most useful website features and identify areas for improvement.
• Cookies and Tracking Technologies: The website employs cookies, web beacons, pixels, embedded scripts, and similar technologies to collect data automatically. A more detailed explanation of these technologies is provided in Section 5 of this policy.

Information from Third Parties

The Company may also obtain personal data from various third-party sources. Examples include:

• MLS/IDX Data: Information related to property listings and potentially consumer contact or budget details shared through Internet Data Exchange (IDX) integration, which allows real estate professionals to display Multiple Listing Service (MLS) data on their websites.
• Business Partners and Service Providers: Data from entities such as payment processors, communications providers, data brokers, or marketing partners.
• Social Media: If users interact with D-Luck Property via social media plugins or share content from the website on social media platforms.

2. How Information is Used

The personal data collected by D-Luck Property is utilized for specific, clearly defined purposes, aligning with the principle of purpose limitation. The processing of this data is always based on a valid legal ground, as required by both the PDPA and, where applicable, the GDPR.

Purpose of Collection

The collected information serves various functions to provide and enhance the services offered:

• Service Provision: To operate and maintain the website’s services, process user inquiries, facilitate property viewings, and manage property listings.
• Personalization and User Experience: To tailor content, personalize the user experience (e.g., by providing relevant property recommendations), and improve overall website functionality.
• Communication: To send transactional emails, respond to user inquiries, and provide essential customer support.
• Marketing and Promotions: To send newsletters, promotional offers, and targeted advertisements. Clear mechanisms for users to manage their preferences or opt-out of such communications are provided.
• Analytics and Improvement: To analyze website usage patterns, track visitor behavior, and gather insights that contribute to the continuous improvement of services and website performance.
• Security and Fraud Prevention: To protect the website and its users from fraudulent activities and ensure the security and integrity of the system.
• Legal Compliance: To fulfill legal obligations and enforce the Company’s terms and conditions.

Legal Basis for Processing

Personal data is processed only when a valid legal basis exists, ensuring compliance with data protection laws. The primary legal bases include:

• Consent: Processing relies on the user’s explicit consent, particularly for activities such as marketing communications, the use of non-essential cookies, or the collection of sensitive personal data. Users retain the right to withdraw their consent at any time.
• Contractual Necessity: Processing is necessary for the performance of a contract with the user or to take steps at the user’s request prior to entering into a contract (e.g., processing inquiries for property viewings or managing account services).
• Legal Obligation: Processing is necessary to comply with a legal obligation to which the Company is subject (e.g., tax regulations, anti-money laundering laws).
• Legitimate Interests: Processing is necessary for the Company’s legitimate interests or those of a third party, provided these interests are not overridden by the fundamental rights and freedoms of the data subject (e.g., for website improvement, network security, or fraud prevention).
• Vital Interest: In rare and specific circumstances, processing may be necessary to protect the vital interests of the user or another natural person.

3. How Information is Shared

We recognize that personal data is a valuable asset that requires careful handling, and we are dedicated to maintaining the highest standards of data protection to earn and preserve our users’ trust. Safeguards are implemented to protect data during these transfers.

Third-Party Service Providers

Users’ personal data may be shared with carefully selected third-party service providers who assist in operating the website and delivering services. These providers are contractually bound to protect the data and use it only for the purposes for which it was disclosed. Examples include:

• Hosting and Infrastructure Providers
• Analytics Providers (e.g., Google Analytics)
• Advertising and Marketing Partners
• Payment Processors
• Customer Support Platforms
• Email Service Providers
• CRM Systems

Legal Requirements and Business Transfers

Personal data may be disclosed under certain legal or business circumstances:

• Legal Compliance: Data may be disclosed if required by law, court order, or governmental request.
• Protection of Rights: To protect the Company’s rights, property, or safety, or the rights, property, or safety of its users or others.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, user data may be transferred as part of the transaction.

4. Cookies and Tracking Technologies

The website www.d-luckproperty.com utilizes cookies and other tracking technologies to enhance user experience, analyze website performance, and deliver relevant content.

What are Cookies?

A cookie is a small text file that a website stores on a user’s computer or mobile device when they visit the site. These files serve to remember user preferences, activities, and browsing history, allowing for a more personalized and efficient online experience.

Types of Cookies Used

• Essential/Strictly Necessary Cookies: Vital for the basic functionality of the website.
• Analytics/Performance Cookies: Collect anonymous data about how users interact with the website.
• Functionality/Preference Cookies: Remember user choices and preferences.
• Advertising/Targeting Cookies: Track browsing history to deliver relevant advertisements.
• Social Media Cookies: Facilitate content sharing on social media platforms.

Your Choices Regarding Cookies

We encourage users to read this policy carefully and contact us with any questions or concerns they may have about our data handling practices.pting, refusing, or deleting them through browser settings. It is important to note that refusing certain cookies may impact the functionality and overall experience of the website.

5. Data Security Measures

The Company is deeply committed to safeguarding personal data and employs a multi-faceted approach to protect it from unauthorized access, loss, or disclosure.

Measures Implemented

• Encryption: SSL certificates (HTTPS) to encrypt data in transit
• Access Controls: Strict access controls for sensitive data
• Strong Password Policies: Enforcement of strong, unique passwords
• Regular Monitoring and Audits: Continuous monitoring and security assessments
• Automated Backups: Regular data backups and disaster recovery plans
• Data Minimization: Collection of only necessary personal data
• Software Updates: Regular security patches and updates
• Employee Training: Regular education on data security best practices

6. Your Data Protection Rights

Users possess statutory rights concerning their personal data, as granted under the Thai Personal Data Protection Act (PDPA) and potentially the General Data Protection Regulation (GDPR), where applicable.

Your Rights Include:

• Right to Access: Request and obtain copies of your personal data
• Right to Receive/Port: Request data in a readable format or transfer to another controller
• Right to Object: Object to the collection, use, or disclosure of your personal data
• Right to Delete/Erasure: Request deletion of your personal data under certain conditions
• Right to Restrict Processing: Request restriction of processing under specific circumstances
• Right to Correct: Request correction of inaccurate or incomplete personal data
• Right to Withdraw Consent: Withdraw consent for data processing at any time

Users can exercise their data protection rights by contacting us through the details provided in Section 9. We are obligated to respond to such requests within 30 days.

7. Data Retention Policy

This policy serves as a comprehensive guide to our data practices, ensuring that users are fully informed about how their information is collected, used, and protected.ssary to fulfill the purposes for which it was collected, or as required by law.

Once the defined retention period expires, or when data is no longer necessary for its original purpose, it is securely deleted or anonymized to prevent unauthorized access or use.

8. International Data Transfers

Personal data collected by D-Luck Property may be transferred to, stored, and processed in countries outside of Thailand, including jurisdictions where data protection laws may differ from those in Thailand.

The Company’s commitment to data protection extends beyond mere compliance; it reflects our core values of transparency, respect for user privacy, and responsible data stewardship. and in compliance with applicable data protection laws.

9. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or the Company’s data protection practices, please contact us:

10. Changes to This Privacy Policy

The Company reserves the right to update or modify this Privacy Policy periodically to reflect changes in its data processing practices, legal requirements, or technological advancements.

Any revisions to this Privacy Policy will become effective immediately upon the posting of the updated policy on www.d-luckproperty.com. For significant or material changes, we will endeavor to provide prominent notice on the website or notify users directly via email.