Privacy Policy
1. Data Controller
| Data Controller | MINAIRAL CO., LTD. (บริษัท มิไนรอล จำกัด) |
|---|---|
| Address | 151/35 Moo 1, Bo Phut, Koh Samui, Surat Thani 84320, Thailand |
| Privacy Contact | info@minairal.com |
| DPO | Not formally designated. All data protection enquiries: info@minairal.com |
2. Personal Data We Collect
2.1 Data You Provide Directly
- Identity: first name, last name
- Contact: email address, phone number, delivery and installation address
- Account: login credentials (password stored in encrypted/hashed form), order history, preferences
- Transaction: order details, payment method type, payment confirmation reference (MINAIRAL does not receive or store full card numbers or bank account details)
- PromptPay: phone number or national ID if provided for refund processing purposes
- Communications: messages and enquiries sent to our support team
2.2 Data Collected Automatically
- Technical: IP address, browser type and version, device type, operating system, screen resolution
- Usage: pages visited, time on site, referral source, click behaviour, cart actions
- Cookie and tracking data: as detailed in the Cookie Policy
2.3 Data Received from Third Parties
| Source | Data Received | Purpose |
|---|---|---|
| Payment gateway (card payments) | Payment authorisation status, transaction reference, masked card details (last 4 digits only) | Order confirmation and fraud prevention |
| PromptPay / BOT network | Transfer confirmation reference, transaction amount | Payment verification |
| Meta (Facebook/Instagram Pixel) | Ad interaction events (page views, add-to-cart, purchase events) | Ad effectiveness measurement and remarketing |
| TikTok Pixel | Ad interaction events (page views, add-to-cart, purchase events) | Ad effectiveness measurement and TikTok audience targeting |
| Google Analytics 4 / Google Ads / Google Shopping | Ad click data, conversion events, website usage data (Google Analytics 4) | Website analytics, Google Ads campaign measurement and Google Shopping performance |
| Shopify | Platform-level analytics, store operations, checkout behaviour | Store management and performance analytics |
| PostHog | Pages visited, clicks, device and browser information, approximate location | Website analytics, to understand how visitors use the shop and improve it |
| Omnisend | Email address (if you subscribe), pages and products viewed, email opens and clicks | Newsletters and marketing emails you have subscribed to |
3. Legal Bases for Processing
| Purpose | Legal Basis | Retention |
|---|---|---|
| Process and fulfil orders | Performance of contract (PDPA s.24(3)) | 7 years (Revenue Code) |
| Customer account management | Performance of contract | Account duration + 1 year |
| Customer support & after-sales | Performance of contract / Legitimate interest | 3 years from last contact |
| Delivery & installation coordination | Performance of contract | 2 years from delivery |
| Transactional emails (order, delivery) | Performance of contract | Duration of relationship |
| Payment processing & fraud prevention | Performance of contract / Legal obligation | 7 years (Revenue Code) |
| PromptPay refund processing | Performance of contract | Until refund confirmed + 1 year |
| Marketing emails / SMS (opt-in) | Explicit consent (PDPA s.19) | Until consent withdrawn |
| Meta Ads remarketing (Pixel) | Legitimate interest; you can object at any time (see section 7) | 90 days (Meta retention) |
| TikTok Ads (Pixel) | Legitimate interest; you can object at any time (see section 7) | 13 months (TikTok retention) |
| Google Ads / Shopping (tags) | Legitimate interest; you can object at any time (see section 7) | 13 months (Google retention) |
| Website analytics (Shopify / GA4 / PostHog) | Legitimate interest; you can object at any time (see section 7) | 13 months |
| Legal & accounting compliance | Legal obligation (Revenue Code) | 7 years |
The Website does not use a consent banner. Analytics and advertising tags (Google Analytics 4, PostHog, Meta Pixel, TikTok Pixel, Google Ads) load when you open a page. You can refuse or limit them at any time with the options in section 7 and in our Cookie Policy.
4. Cross-Border Data Transfers
MINAIRAL uses third-party services that involve transferring personal data outside Thailand. The following table documents each transfer, destination, and applicable safeguard in accordance with PDPA Sections 28 to 29 and the PDPC Cross-Border Transfer Notification (effective March 2024):
| Service / Provider | Data Transferred | Destination | Safeguard |
|---|---|---|---|
| Shopify (store platform) | Customer identity, contact, order history, browsing behaviour | USA / Canada | Shopify Data Processing Agreement, Standard Contractual Clauses (SCCs) |
| Payment gateway (card) | Transaction reference, masked card data, amount | Thailand / regional processing | PCI-DSS certified, Bank of Thailand regulated |
| PromptPay / BOT network | Transfer confirmation, amount | Thailand (domestic) | BOT-regulated domestic network, no cross-border transfer |
| Meta (Facebook/Instagram) | Pixel event data (page views, conversions) | USA / Ireland | Meta Data Processing Terms, SCCs |
| TikTok | Pixel event data (page views, conversions) | USA / Singapore | TikTok Data Processing Agreement, SCCs |
| Google Ads / Shopping / Analytics | Ad click data, conversion events, analytics | USA / EEA | Google Ads & Analytics DPA, SCCs |
| PostHog (website analytics) | Pages visited, clicks, device and browser information | USA | PostHog Data Processing Agreement |
| Omnisend (email marketing) | Email address, browsing activity on the shop, email opens and clicks | Outside Thailand (provider's servers) | Omnisend Data Processing Agreement |
Customers may request information about the specific safeguards in place for any cross-border transfer by contacting info@minairal.com.
5. How We Use Your Data
- To process, confirm, and fulfil your orders (purchases, delivery coordination, installation booking)
- To process payments via the accepted payment methods and manage refunds
- To send transactional communications (order confirmation, dispatch notification, filter replacement reminders)
- To manage your customer account and order history
- To respond to customer service and after-sales enquiries
- To measure and improve the performance of our advertising campaigns on Meta, TikTok, and Google
- To personalise advertising shown to you on Meta, TikTok, and Google platforms
- To analyse Website traffic and user behaviour to improve Website performance (Shopify analytics, Google Analytics 4 and PostHog)
- To comply with legal obligations under Thai law (tax, accounting, consumer protection)
- To send newsletters and marketing emails you have subscribed to (Omnisend). Every email has an unsubscribe link
6. Data Sharing
We do not sell your personal data. We share data only with:
| Recipient | Data Shared | Basis |
|---|---|---|
| Courier and logistics partners | Name, delivery address, phone number, order reference | Performance of contract, delivery |
| Payment gateway provider | Transaction amount, currency, order reference | Performance of contract, payment processing |
| Shopify (platform provider) | Full order and customer data as required to operate the store | Data processing agreement |
| Meta / TikTok / Google (ad platforms) | Pixel event data only, no personally identifiable data sent directly | Legitimate interest |
| PostHog / Omnisend (analytics and email providers) | Website usage data, and your email address if you subscribe | Data processing agreement |
| MINAIRAL installation subcontractors | Name, installation address, phone number, appointment date | Performance of contract, installation service |
| Government authorities | As required by Thai law (Revenue Department, DBD, courts) | Legal obligation |
| Professional advisors | As required for legal, accounting, or audit purposes | Legitimate interest, confidentiality obligations apply |
7. Your Rights Under the PDPA
| Right | Description | How to Exercise |
|---|---|---|
| Right to be informed | Know what data we collect and how we use it | This Privacy Policy |
| Right of access | Receive a copy of personal data MINAIRAL holds about you | Email info@minairal.com |
| Right to rectification | Correct inaccurate or incomplete data | Email info@minairal.com |
| Right to erasure | Request deletion where legally permitted ('right to be forgotten') | Email info@minairal.com |
| Right to restriction | Restrict processing in certain circumstances | Email info@minairal.com |
| Right to portability | Receive your data in a structured, machine-readable format | Email info@minairal.com |
| Right to object | Object to processing based on legitimate interests or direct marketing | Email info@minairal.com, or block cookies in your browser |
| Refuse or limit tracking | Block or delete cookies, opt out of Google Analytics and personalised ads, unsubscribe from emails | Browser settings, Google Analytics opt-out add-on, Meta and Google ad settings, unsubscribe link in each email (details in the Cookie Policy) |
We respond to all requests within 30 days. You have the right to lodge a complaint with Thailand's Personal Data Protection Committee (PDPC) if you believe your rights have been violated.
8. Data Security
We implement appropriate technical and organisational security measures including: SSL/TLS encryption for all Website transmissions; PCI-DSS compliant payment processing (no card data stored by MINAIRAL); access controls and role-based authentication for internal systems; and regular security reviews.
In the event of a personal data breach presenting a risk to your rights, we will notify the PDPC within 72 hours and inform affected individuals without undue delay in accordance with PDPA Section 37.
9. Children's Data
Our Website is not directed at individuals under 20 years of age. We do not knowingly collect personal data from minors. Contact info@minairal.com if you believe a minor has submitted data through our Website.
10. Cookies & Advertising Technologies
We use cookies and tracking tags from Google (Analytics 4 and Ads), PostHog, Meta, TikTok and Omnisend on the Website. They load when you open a page; there is no consent banner. The Cookie Policy explains what each one does and how to refuse or limit them.
11. Updates to This Policy
We may update this Privacy Policy to reflect changes in our practices, the services we use, or legal requirements. Material changes are communicated by email or via a prominent Website notice at least 30 days before taking effect. The updated date is shown at the top of this Policy.
12. Contact
| Data protection enquiries | info@minairal.com |
|---|---|
| General support | info@minairal.com |
| Phone | +66 82 113 0501 |
| Address | MINAIRAL CO., LTD. │ 151/35 Moo 1, Bo Phut, Koh Samui, Surat Thani 84320, Thailand |
| PDPC complaint | https://www.pdpc.or.th |