Modulo currently operates as an unregistered trading name. Before public launch, these pages must identify the responsible individual or individuals, include a contact address and effective date, confirm DPO status, and be reviewed by qualified Thai legal counsel.
This page explains how Modulo handles Personal Data across the Website, enquiries, client engagements and related services.
1. Introduction
This Privacy Policy explains how Modulo, the operator of modulo-web.com, collects, uses, discloses, transfers, retains and otherwise processes Personal Data under Thailand’s Personal Data Protection Act B.E. 2562 (2019) and applicable subordinate rules. It is intended to provide the notice required under Section 23 of the PDPA.
2. Data Controller and contact details
Modulo is currently an unregistered trading name used by the team operating this Website. The full legal identity and contact address of the individual or individuals responsible for deciding how Personal Data is processed must be inserted before publication. Privacy enquiries may be emailed to modulo.incservice@gmail.com or made by telephone at +66 98-570-8638.
The team at Modulo must confirm whether a Data Protection Officer is required under Section 41 of the PDPA and publish either the appointed DPO’s details or the supplied no-DPO statement.
3. Scope of this Policy
This Policy applies to website visitors, enquirers and prospective clients, clients and their personnel, course and content participants, suppliers, contractors, freelancers, business partners, and job applicants. It does not govern third-party websites or Personal Data controlled by clients where Modulo acts only as a Data Processor.
4. Definitions
Personal Data means information relating to an identifiable living person. Sensitive Personal Data includes the categories identified in Section 26 of the PDPA. Data Subject, Data Controller, Data Processor and Processing have the meanings given by the PDPA.
5. Personal Data we collect
Information provided directly may include enquiry details, client and contract information, payment evidence, project content, platform credentials, course and marketing preferences, communications, and recruitment information.
Information collected automatically may include IP address, approximate location, browser and device details, pages viewed, referral information, interaction data, cookies, identifiers, server logs and security events. Information may also come from analytics platforms, social networks, referrers, partners and public business sources.
Modulo does not seek Sensitive Personal Data and the Website is directed at businesses rather than children. Any necessary processing of Sensitive Personal Data or minors’ data must follow the explicit consent and guardian requirements of the PDPA.
6. Purposes and lawful bases
Personal Data may be processed to respond to enquiries, prepare proposals, deliver services, issue invoices, meet tax and accounting duties, secure and maintain the Website, measure performance, conduct consent-based marketing, deliver education, publish approved portfolio work, manage suppliers and recruitment, prevent fraud, handle legal claims and support corporate transactions.
The applicable lawful bases include contractual necessity, legal obligation, legitimate interest and consent. Where consent is relied upon, it may be withdrawn at any time without affecting earlier lawful processing.
7. Consequences of not providing data
Providing Personal Data is generally voluntary, but Modulo may be unable to answer an enquiry, enter or perform a contract, issue compliant invoices, access required platforms or deliver particular services if necessary information is withheld. Declining non-essential cookies will not prevent the core Website from functioning.
8. Cookies and similar technologies
The Website may use strictly necessary, functional, analytics and advertising technologies. Non-essential cookies must be blocked until consent is given. The banner must offer equally prominent accept and reject choices, granular preferences, a record of consent, and an accessible footer link for changing choices.
Before publication, Modulo must scan the live Webflow site and replace examples with the actual cookies, providers and durations in use.
9. Disclosure of Personal Data
Modulo does not sell Personal Data. Necessary disclosures may be made to hosting and domain providers, analytics and advertising platforms, email and CRM tools, project and collaboration systems, payment providers and banks, professional advisers, vetted contractors, government authorities and confidential corporate-transaction counterparties.
Processors must be governed by appropriate written data-processing obligations under Section 40 of the PDPA.
10. International transfers
Some providers, including Webflow, Google, Meta and TikTok, may process information outside Thailand. Transfers must follow Sections 28 and 29 of the PDPA through adequacy, appropriate safeguards, contractual necessity, explicit informed consent or another lawful exception.
11. Your rights
Subject to PDPA conditions, Data Subjects may request information, access, correction, portability, objection, erasure or anonymisation, restriction, withdrawal of consent and complaint review. Requests should be submitted to modulo.incservice@gmail.com and Modulo will normally respond within 30 days unless a lawful extension applies.
Requests are generally free, but a reasonable fee or refusal may apply where permitted for manifestly unfounded or excessive requests. Identity verification may be required. Complaints may be made to the Office of the Personal Data Protection Committee.
12. When we act as a Data Processor
Where Modulo builds or operates a client system and processes Personal Data only on that client’s instructions, the client is the Data Controller and Modulo is the Data Processor. The parties should enter a Section 40-compliant Data Processing Agreement governing instructions, confidentiality, security, sub-processors, assistance, breach notification and deletion or return.
13. Data retention
Personal Data is retained only as long as necessary for its purpose and legal obligations. The supplied draft proposes category-specific periods for enquiries, contracts, tax and accounting records, credentials, project content, analytics, marketing, recruitment, consent records, Data Subject requests and processing logs. These periods must be confirmed against Modulo’s actual systems and obligations before publication.
14. Security measures
Modulo uses organisational and technical safeguards appropriate to risk, including access controls, authentication, encryption in transit, secure credential sharing, confidentiality duties, processor contracts, backups, logging, awareness, device disposal and periodic review. No internet transmission or storage method can be guaranteed completely secure.
15. Personal data breach notification
Where a breach creates a risk to individuals, Modulo will notify the Office of the PDPC without undue delay and, where feasible, within 72 hours of awareness. Where the breach is likely to create a high risk, affected individuals will also be informed without undue delay, subject to applicable exceptions.
16. Automated decision-making and profiling
Modulo does not make decisions producing legal or similarly significant effects solely through automated processing. Advertising platforms may perform limited profiling for audience selection, subject to consent and the right to object.
17. Third-party links and platforms
The Website may link to external platforms including Instagram, Facebook, TikTok and Webflow resources. Those providers control their own processing, and visitors should review their privacy notices before providing information.
18. Records of processing activities
Modulo maintains records required by Section 39 of the PDPA covering categories of data and individuals, purposes, recipients, transfers, retention, security measures, rights requests and incidents.
19. Changes to this Policy
Modulo may update this Policy to reflect changes in processing, providers or law. The current version and update date will be published here. Material changes may be communicated by a prominent notice or direct message where appropriate.
20. Contact us
Questions, requests and complaints may be emailed to modulo.incservice@gmail.com. Telephone: +66 98-570-8638. Website: https://modulo-web.com. The responsible operator’s full legal identity and contact address must be inserted before publication.
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