Privacy Policy

This Privacy Policy explains how ThaiSmiley collects, uses, generates, stores, discloses, and otherwise processes personal data when you use our websites, early-access pages, dating and discovery features, profile tools, messaging, media, verification, subscriptions, notifications, support, and related services (together, the Service). It also explains your choices and applicable rights.

ThaiSmiley, we, us, and our currently refer to the service operated temporarily by AP Consulting, which is responsible for the purposes and handling of personal data described here. A future change of operator will be reflected in this notice and communicated as required before responsibility changes.

This policy applies to personal data we control. A linked website, app store, payment page, social-login provider, or other third party may process data under its own notice. Where we process information only on another organisation's documented instructions, that organisation is responsible for its own notice and lawful basis.

If you choose Google sign-in, Google shares your account identifier, email address and its verified status, and basic profile information such as your name and profile picture with Clerk, our authentication provider. We use this information to authenticate you, create or link your account, and maintain your sign-in session. Your Google password is not shared with ThaiSmiley.

The Google sign-in connection requests only identity, email, and basic profile access. It does not request access to your Gmail messages, Google Drive files, contacts, or calendar. Basic Google account information used for sign-in is separate from the dating profile information you choose to publish on ThaiSmiley.

Clerk processes and stores the connected identity and session information. ThaiSmiley stores the Clerk user identifier and account email in its application database. Account information is retained while needed to provide your account and handle security or legal requirements, subject to the retention and deletion section below. Contact hello@thaismiley.com to request deletion of your account data.

You can review or revoke ThaiSmiley's Google connection in your Google Account connections. Revoking Google access does not by itself delete your ThaiSmiley account or its stored data.

Dating services involve deliberate sharing with other people. Before using ThaiSmiley, please understand:

• Profiles and profile media require sign-in. During private prelaunch, ordinary members can manage their own profiles; discovery and messaging are reserved for authorised staff and private testers. See section 5 for the profile audience and access limits.
• Your email address, telephone number, authentication identifiers, full date of birth, and exact stored coordinates are not intended to appear on your dating profile. Your chosen display name, age or age range, city or distance, photos, voice introduction, video, and other chosen profile fields may appear.
• Messages are not end-to-end encrypted. Recipients may save, forward, record, or screenshot anything you share, and push notifications may be visible on a locked device.
• Sexual orientation, gender identity, sexual role, relationship intentions, location, and face or voice media can be particularly sensitive. Add them only when you are comfortable with the stated audience.
• Do not upload intimate content, another person's information or image without permission, government identifiers, financial credentials, or anything you would not want a recipient to retain.
• Core privacy rights are never conditioned on buying a membership. Some optional visibility or activity controls may be plan features, as shown in the Service.

Blocking, reporting, visibility, notification, location, and profile controls, where available and operational, can reduce exposure but do not make information already seen or copied by another person disappear.

What we collect depends on the features you use, your settings, your device, and your location. Required fields are identified in the relevant screen. Optional fields can generally be left blank or removed, although previously shared copies may remain as described in this policy.

Account and identity data

Email address, telephone number if supplied, verified status, authentication and social-login providers, account and session identifiers, account status and role, sign-up time, and whether an account is a tester, demo, staff, or administrator account. Authentication providers may also return basic account data permitted by you.

Profile and dating data

Display name and username, headline, biography, date of birth and age, city, gender identity, sexual orientation, sexual role, relationship intention, height, weight, languages and language ability, education, whether you have or want children, and the genders and age range you want to meet.

Photos, audio, and video

A processed large profile-photo version and resized variants, crops, thumbnails, blur placeholders, file metadata and checksums (the untouched source file is not necessarily retained); voice introductions and voice messages, duration, waveform, format and size; profile-video uploads, processed streams, playback identifiers, posters and thumbnails; chat images; and accompanying content.

Location data

A city you type or select, city and place identifiers, latitude and longitude returned by a mapping provider, or precise browser/device coordinates if you grant location permission. We may derive city, country, and distance from coordinates.

Interactions and communications

Likes, Super Likes, passes, favourites, matches, profile visits, search filters and saved searches, message content and attachments, message reactions, delivery and read status, blocks, reports, support messages, and communication preferences.

Verification and face-analysis data

Verification challenge and attempt identifiers, selected selfie sample frames, media hashes, face landmarks or blendshape and activity signals, liveness and image-quality scores, pose and lighting measurements, completion results, risk flags, reviewer decisions, appeal information, and related device/browser data. Depending on the jurisdiction and use, some of this may be biometric data.

Safety, moderation, and derived data

Automated and human moderation results, content labels, confidence or risk scores, detected policy categories, report evidence, enforcement history, chat-watchlist reasons and access-audit records, duplicate or abuse signals, profile completeness, verification status, distance, recency, compatibility or ranking signals, and inferences used to operate discovery and protect the Service.

Payments and membership

Plan, price and product identifiers, subscription and payment-customer identifiers, transaction and invoice status, renewal and cancellation dates, currency and aggregated spending data, promotion or founding-member eligibility, reward position and status. Payment processors handle card or payment credentials; ThaiSmiley is not designed to store full card numbers or security codes.

Device, usage, and network data

IP address, browser and device type, user agent, operating system, language, time zone, referral and page information, coarse region, session and security events, feature activity, timestamps, performance and error data, rate-limit events, and identifiers stored in cookies or browser storage. We minimise page addresses sent to analytics by removing query strings, fragments, and profile IDs.

Notification and marketing data

Email locale, consent and unsubscribe history, delivery, bounce and suppression events; web-push endpoint, encryption keys, user agent and delivery state; notification settings; and the content and timing of account, safety, membership, message, profile-visit or product notices.

Where the data comes from

We receive data directly from you; automatically from your device and use of the Service; from other members who interact with, block, or report you; from authentication, payment, hosting, communications, media, maps, analytics, and safety providers; and from staff who review support, moderation, or verification matters. We may receive data from lawful public sources when necessary to investigate fraud, abuse, or a safety incident. We do not ask contacts to upload an address book for matching in the current Service.

The legal basis depends on the activity and law that applies. Where required, we document and rely on one or more of the following bases:

Provide the Service and perform our contract

Create and secure accounts; build profiles; publish content you choose; provide search, discovery, matching, messaging, media, settings, subscriptions and support; process requested payments; administer early-access rewards; and communicate necessary service information.

Your consent

Use device location, microphone, camera, optional cookies or similar technologies, direct marketing, and—where law requires—sexuality-related, biometric, face-analysis, voice, or other sensitive data. Consent is specific to the notice and control presented; one consent is not blanket permission for unrelated uses.

Legitimate interests

Protect members and the Service; moderate content; detect fraud, spam, fake accounts and abuse; investigate reports; measure and improve performance; understand feature use; keep internal records; establish or defend legal claims; and responsibly develop the Service, after balancing those interests against your rights and reasonable expectations.

Legal obligations and public interests

Keep records required by law; respond to valid legal process; protect data-subject rights; handle complaints and security incidents; meet tax, accounting, consumer, payment, sanctions, and regulatory duties; and assist authorities where legally required.

Vital interests and safety

In a genuine emergency, use or disclose information reasonably necessary to protect a person's life, health, or physical safety, where applicable law permits.

In jurisdictions that recognise special-category or sensitive data, information about sexual orientation or sex life and face data used to verify identity may require an additional condition, commonly explicit consent or a substantial public-interest or legal-claims condition. We will present a separate, just-in-time choice where required. You may withdraw consent prospectively, but withdrawal does not make earlier lawful processing unlawful and may make an optional feature unavailable.

We will not use materially different purposes without assessing compatibility and, when required, giving notice or obtaining new consent.

Who can see a profile

Signed-out visitors cannot view member profiles, search results, or profile media. During private prelaunch, an ordinary member can create and manage their own profile, while authorised personnel may access it for support, moderation, and service operation. Discovery and messaging are restricted to authorised staff and private testers, and ordinary prelaunch profiles are excluded from that discovery.

When public launch is enabled, authenticated members may view eligible profiles according to the applicable discovery settings. Hiding a profile from search also prevents other members from retrieving its profile details or profile media through a direct address. Account holders and authorised staff retain appropriate access. Intended viewers may still copy or share information they can see.

A profile may show a derived age, join-date or activity indicator, city or distance, verification badge, and membership badge depending on your settings. Exact coordinates, full birth date, account email, telephone number, payment identifiers, and internal moderation data are not intended to be shown as public profile fields.

The current profile-detail implementation can also reveal whether a paid plan renews or ends and the relevant date to another eligible authenticated member. ThaiSmiley does not need another member's private billing cycle for matching and intends to remove that detail before general availability.

How recommendations and ordering work

Discovery and Quick Likes can use your filters and preferences, other members' preferences, location and distance, recent activity, profile completeness, photo verification, mutual interest, safety and moderation status, and membership plan. Quick Likes currently gives a larger ordering boost to higher paid plans and also weights recency, distance, and verification. Standard search does not currently order results by that paid boost. Search and recommendation systems may evolve, but safety and legal-rights handling are not sold as plan benefits.

Opening an eligible profile can automatically record a profile visit with the visitor, viewed member, and time unless the visitor's server-enforced hide-visits setting is active. Authenticated pages also report live-presence heartbeats and periodically update last-active time. A random browser-tab identifier, focus and visibility state, and recent timestamp are held locally; live state is held briefly in managed Redis while a longer-lived last-active timestamp is stored in the profile database. These signals support online labels, recency ordering, and “smart” notification suppression.

Automated moderation and decisions

Automated tools may flag or block a username, message, image, verification attempt, suspected spam, or other activity; quarantine content pending review; calculate risk or quality scores; or change ordering. Human moderators may confirm, reverse, or supplement these results. These tools are designed for content safety, integrity, recommendations, and feature access—not to make decisions producing legal or similarly significant effects without safeguards required by applicable law. Contact us to contest an enforcement or verification result and request human review where applicable.

Profile media, messages, and attachments are not end-to-end encrypted. Intended viewers, recipients, and authorised safety or support personnel may access them as described here. A recipient may copy, download, screen-record, forward, or otherwise retain shared media beyond your control. If an upload contains another identifiable person, you represent that you have a lawful basis and any necessary permission to share it.

Do not upload nudity or sexual content involving anyone under 18, non-consensual intimate imagery, exploitative content, hidden recordings, or unlawful material. We may preserve and disclose relevant data when required for safety reporting, valid legal process, or the establishment, exercise, or defence of legal claims.

ThaiSmiley uses two distinct face-processing flows. First, optional on-device face detection can suggest a crop for a profile photo. Second, optional photo verification can compare live activity and captured samples with your profile photo to assess whether a real person is present and whether the submitted images appear consistent. Immediately before each verification attempt, we present a separate unticked consent choice. Its exact notice controls that attempt and should be read together with this policy.

• On-device processing. The verification recording is analysed in the browser. The current implementation does not upload or store the complete recorded video.
• Data sent to us. A limited set of selfie sample frames, a media hash, prompt-completion information, face landmarks or blendshape/activity signals, liveness and quality scores, pose and lighting measurements, flags, timestamps, challenge identifiers, and browser user agent may be sent to and stored by ThaiSmiley for verification and review.
• Software delivery. MediaPipe model and code files may be fetched from jsDelivr and Google storage infrastructure. If the separate MediaPipe metrics option is enabled, package-level usage or diagnostic metrics may be sent to Google under the notice shown with that choice.
• Review. Hard safety or quality failures can reject an attempt automatically; other attempts may be sent to an authorised human reviewer. Approved accounts may receive a profile badge.
• Limits. The current flow does not request a government identity document or search an external face-identification database. It is not intended to infer ethnicity, health, emotion, sexual orientation, or other unrelated traits.

We will publish and apply a biometric retention and destruction schedule before offering verification broadly. Unless law requires otherwise, biometric identifiers will not be sold, leased, traded, used for advertising, or disclosed for an unrelated purpose. We will not materially expand face or voice identification uses without a new assessment, notice, and consent where required.

You can select or type a city, or ask your browser/device to provide its current location. If you use device location, exact latitude and longitude may be sent through our server to Google for reverse geocoding and then stored with your profile. If you type a location, the search text and a session token may be sent to Google Places, and the selected result can return coordinates and place identifiers.

We use location to populate your city, calculate distance, apply search radiuses, order or recommend profiles, and detect misuse or impossible activity. Other members may see a city or calculated distance, subject to privacy settings; they are not intended to receive your exact stored coordinates through a profile response. Distance and city can still allow someone to infer where you live or travel, especially in a small area.

Device location requires operating-system or browser permission. You can deny or revoke it and enter a city manually. You can also adjust whether distance appears where that setting is available. Revoking device permission stops future device collection but does not automatically erase location already stored; update the profile or request deletion for that.

We process messages, attachments, reactions, delivery and read status, and conversation participants to deliver chat. Depending on your settings and plan, members may be able to control who can message them, read receipts, activity visibility, profile-visit visibility, and online presence. Blocking restricts future interaction but does not necessarily remove data already exchanged or retained for safety.

To prevent abuse and enforce our rules, usernames and chat text may be submitted to OpenAI moderation, and profile photos may be submitted to OpenAI moderation and vision services. We may store returned labels, scores, explanations, flags, and review status. Images in chat can be quarantined for human review. Reports may contain the reporter, reported account or content, reason, description, evidence, status, timestamps, and reviewer action. We disclose only what is reasonably necessary to reviewers and ordinarily do not tell a reported person who made the report.

Authorised staff may review relevant accounts, profiles, photos, verification material, messages, or reports when reasonably necessary to investigate a complaint, enforce rules, support a member, protect a person, debug a reported problem, or meet a legal duty. Staff access should be role-limited and logged. Moderation providers process submitted content under their own contractual and technical safeguards; do not assume content submitted to a third-party AI service is anonymous.

For a documented safety, support, or abuse-investigation purpose, the authorised owner may place a selected member account on a persistent chat watchlist. This permits read-only review of that member's conversations and attachments until the owner explicitly revokes the watch. It does not change message read receipts or online presence. Creating or revoking a watch requires fresh multi-factor verification, and each conversation-list, transcript, and attachment access is recorded in a restricted audit log.

We may suspend or restrict accounts, block content, revoke a promotion, preserve evidence, warn members, or report conduct to authorities where reasonably necessary and legally permitted. You may contact us to contest a material moderation or enforcement action.

We use account email or push subscription data to send authentication, security, support, account, membership, profile-completion, message, interest, profile-visit, and other service notices. A web-push subscription contains an endpoint and encryption keys issued by the browser's push service. Delivery may involve Apple, Google, Mozilla, or another browser or operating-system push provider.

Current social push notifications use generic text rather than message content or a member's name and can include an event type and a link into the Service. A provider payload can technically support an icon or image, but ThaiSmiley does not currently add a member's private profile photo. Visible notification content may appear on a lock screen or shared device depending on device settings. Disable or limit previews in the Service or operating system where that option is available.

Resend supports transactional and permitted marketing email, including delivery, bounce, complaint, unsubscribe, and suppression handling. Clerk or an authentication provider may separately deliver sign-in or verification messages. Stripe may send payment receipts or subscription notices. You cannot opt out of communications that are strictly necessary for security, transactions, or the Service, but you can manage optional marketing and many product notifications in settings or through the unsubscribe control.

The Service and our providers use cookies, local storage, session storage, cache entries, pixels or similar technologies for authentication, security, fraud prevention, language and interface preferences, feature state, saved search and profile lists, early-access progress, notification settings, consent records, performance, and analytics. Authentication cookies are generally necessary to keep you signed in and prevent misuse.

Browser storage may remember sidebar state, online-presence state, likes, favourites or messaging markers, Quick Likes cache and prompts, privacy or notification choices, and whether early-access sign-up began. It remains on the device until it expires, the app replaces it, or you clear it. Clearing browser data may sign you out or reset preferences but does not erase server records.

Vercel Analytics and Speed Insights may receive page, device, network, region, performance, and visit data to measure reliability and usage. We remove query strings, URL fragments, and recognisable profile IDs from page paths before sending our analytics page address. Provider-side network logs may still include an IP address and user agent. We do not currently use third-party advertising trackers or intentionally exchange personal data for money or cross-context behavioural advertising. Final contracts and flows must still be assessed under each law's definitions of sale and sharing before launch.

The current prelaunch build does not yet include a cookie or analytics preference centre and mounts Vercel Analytics and Speed Insights globally. Before general availability in a jurisdiction that requires prior consent for a configured technology, we will implement the required choice and will not activate that technology until consent. Browser “Do Not Track” signals do not have one universally accepted meaning; the Service does not currently change behavior solely in response to DNT. If we ever engage in regulated sale, sharing, or targeted advertising, we will provide the required opt-out and honour applicable Global Privacy Control signals.

We disclose personal data only for the purposes described in this policy. Providers currently act under their applicable service terms and technical access controls. Before commercial launch, ThaiSmiley will complete and document any data-processing agreements, transfer terms, and additional role controls required for the final configuration. Current or planned provider categories include:

Authentication

Clerk and, if you choose them, Google, Facebook/Meta, or Apple social sign-in.

Hosting, storage, and database

Vercel hosting and Blob storage, and a PostgreSQL database provider.

Media delivery

Mux for profile-video upload, processing, streaming, thumbnails, and asset deletion.

Safety and AI processing

OpenAI for configured text and image moderation and related safety review.

Maps and face-processing assets

Google Maps/Places/Geocoding, Google-hosted model assets, and jsDelivr content delivery.

Real-time and infrastructure

Ably for real-time chat/presence and Upstash for managed Redis-based service state.

Communications

Resend for email and browser/operating-system push services for web notifications.

Payments

Stripe for checkout, billing, subscriptions, receipts, fraud controls, and payment records.

Analytics and diagnostics

Vercel Analytics and Speed Insights, plus operational logging and error diagnostics.

A provider is listed by function, not as permission for every product it offers. Final provider legal names, processing locations, retention, subprocessors, and contract links will be confirmed in a published subprocessor register before commercial launch. We will update that register before enabling a materially new production processor, including any alternative high-risk payment processor.

Other circumstances

• Other members and the public: receive the profile, media, interaction, or message data you choose to make available to them.
• Professional advisers and insurers: may receive information reasonably necessary for legal, audit, tax, security, insurance, and corporate-administration services.
• Authorities and safety recipients: may receive information in response to binding legal process or when disclosure is legally permitted and reasonably necessary to protect rights, safety, or the public. We assess requests and challenge overbroad demands where appropriate.
• Corporate transactions: a potential or completed investor, financing source, buyer, successor, insolvency administrator, or reorganisation participant may receive data under appropriate confidentiality and legal safeguards. We will notify you of a controller change when required.
• At your direction: we disclose data when you request or clearly authorise an integration or transfer.

ThaiSmiley does not intentionally exchange personal data for money or disclose it for cross-context behavioural advertising. We do not disclose biometric information to data brokers or advertisers. Before commercial launch, final data flows and contracts will be assessed against each applicable law's broader definitions; if a regulated sale or sharing activity occurs, we will provide the required notice and opt-out.

ThaiSmiley's temporary operator, AP Consulting, has its contact address in Egypt and serves people internationally. Our providers, personnel, members, and systems may be located in Egypt, Singapore, Thailand, the United States, the European Economic Area, the United Kingdom, and other countries. As a result, personal data may be processed outside the country where you live, under laws that may differ from local law.

Before production launch, we will document the actual hosting and provider regions and implement legally required transfer safeguards. Depending on the transfer, these may include adequacy regulations, Singapore-comparable protection obligations, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, contractual confidentiality and security terms, transfer-risk assessments, and supplementary technical or organisational measures. You may request information about the safeguard relevant to your data, subject to lawful redactions.

Our required retention principle is to keep each category only as long as reasonably necessary for the purposes described, including to provide an active account, maintain safety and transaction records, comply with law, resolve disputes, enforce agreements, and establish, exercise, or defend legal claims. We consider sensitivity, volume, purpose, risk, legal limitation periods, provider backup cycles, and whether data can be reliably anonymised. The current prelaunch implementation does not yet enforce a complete category-by- category deletion schedule, so the periods below are criteria and launch requirements rather than a claim that every cleanup job is already automated.

Active account and profile

Generally retained while the account remains active and then deleted or anonymised under the closure schedule.

Messages and shared media

Retained to provide conversation history and safety functions. Closing one account does not necessarily remove the copy visible to another participant. Separate object files must also be deleted from media storage.

Reports, blocks, fraud, and enforcement

Reports, blocks, watchlist records, restricted watchlist-access logs, and related enforcement evidence are retained for a proportionate period after closure where needed to prevent repeat abuse, protect members, support appeals, comply with law, or defend claims.

Payments and subscriptions

Retained for applicable tax, accounting, chargeback, anti-fraud, and consumer-law periods.

Analytics and operational logs

Intended to be kept for short operational periods or aggregated/anonymised where practicable. Final provider and application periods must be documented and configured before launch.

Backups

If providers retain backup copies, they should be isolated from ordinary use and removed on documented rotation cycles unless a legal hold applies. Final provider cycles remain to be confirmed before launch.

Browser storage

Remains until expiry, replacement, or deletion through browser or device controls.

Verification data

Handled under the shorter, separately documented face/biometric schedule described above.

When a valid deletion request is completed, we will delete, de-identify, or restrict personal data across active systems and instruct processors as appropriate, except data we must or are permitted to keep. We will explain material exceptions. De-identified or aggregated information that cannot reasonably be linked to a person may be retained. A deleted member's messages may remain for recipients with the sender de-identified, where legally permitted and necessary for conversation integrity or safety.

We use risk-based safeguards intended to protect confidentiality, integrity, and availability. These include authenticated routes, role and conversation access checks, private or signed media delivery for supported profile media, encrypted transport, provider secret management, webhook signature validation, rate limiting, moderation and abuse controls, audit logging, and restricted administrative access. Safeguards will be reviewed as the Service and risks change.

No system is perfectly secure. Account holders must protect sign-in credentials and devices, use official links, keep software current, and report suspected compromise promptly. Do not send passwords, one-time codes, financial credentials, or government identification through profile or chat fields.

Before general availability, ThaiSmiley will document and test an incident process to investigate, contain, remediate, record, and assess suspected personal data breaches. Prelaunch incident reports will be investigated through the privacy contact. When law requires, we will notify the relevant regulator, affected individuals, or business partners within the applicable time and with the required information. Report a suspected privacy or security incident to hello@thaismiley.com.

Depending on where you live and the applicable law, you may have rights to be informed; access and receive a copy; correct; delete; restrict or object to processing; withdraw consent; obtain portable data; opt out of sale, sharing, targeted advertising, or certain profiling; limit use or disclosure of sensitive data; contest or obtain human review of certain automated decisions; and complain to a regulator. You may also have a right not to receive discriminatory treatment for exercising a privacy right.

In-product controls

Edit profile data; choose publication and search visibility; manage activity, read receipt, join-date, age, distance, visit, online-presence and messaging controls where they are shown as saved and operational; manage notifications; use available block or report tools; revoke browser permissions; and delete individual profile media.

Make a request

Email hello@thaismiley.com with the account email, the right you want to exercise, and enough detail to locate the data. Do not email a password, identity document, or unnecessary sensitive data.

Verification and agents

We may verify account control or request proportionate information to prevent fraudulent disclosure or deletion. An authorised agent may submit a request where law permits, subject to proof of authority and direct verification where allowed.

Response and appeal

We will acknowledge, respond, extend, charge, or refuse only as permitted by applicable law, explain a refusal, and provide an appeal or regulator route where required. Rights can be limited by the rights of others, legal privilege, safety, fraud prevention, or another lawful exception.

An account closure request is not the same as hiding a profile, signing out, uninstalling an app, or cancelling a paid subscription. Cancel recurring billing before closure where required by the checkout flow. We will coordinate linked requests but may need to confirm each requested outcome.

These summaries supplement, rather than replace, the rest of this policy. A law applies according to its own scope and exemptions, not simply because it is listed here.

ThaiSmiley is an adults-only dating Service. You must be at least 18 and also meet any higher minimum age required to use a dating service where you live. We do not knowingly permit a person under 18 to create an account, appear in dating profile media, exchange messages, or use verification.

In the current onboarding sequence, an authentication record can be created before date of birth is collected. The adult-age check is enforced when a dating profile is completed. Before general availability, ThaiSmiley will add an earlier age gate and a documented process for prompt restriction and deletion of suspected underage accounts.

Do not upload photos, recordings, school details, contact information, location, or other personal data of a child, even if you are the parent or guardian. Limited statements about whether you have or want children do not authorise child data or images. If you believe a minor has used the Service or appears in content, contact hello@thaismiley.com immediately. We may suspend access, investigate, preserve legally required safety evidence, and delete or report the data as appropriate.

We will update this policy before public launch to confirm any operator changes, final provider and transfer details, validated retention periods, regional representatives, and any material feature changes. After launch, we may update it as the Service, law, risks, or providers change. The “last updated” date and version identify the current notice.

For a material change, we will provide prominent or direct advance notice when required and request new consent before a use that cannot lawfully rely on the existing notice or basis. Changes do not retroactively legalise earlier processing. We intend to keep prior versions available once the Service launches.

Because the Service is directed to people in Thailand as well as international members, a professionally reviewed Thai-language notice will be published before public launch in Thailand. Until then, contact us if you need help understanding this English prelaunch draft.