Privacy Policy

1. Data Controller

The data controller for all personal data collected through this website and our services is Nimano, operating from 88 Phaya Thai Road, Ratchathewi, Bangkok 10400, Thailand. For data-related enquiries, contact us at [email protected].

2. Data We Collect

We collect personal data in the following ways:

• Contact form submissions: name, email address, phone number (optional), and message content.
• Direct correspondence: email address and any personal data included in communications you initiate.
• Website analytics: anonymised or pseudonymised usage data including pages visited, browser type, device type, and approximate geographic location (country/city level). This data is collected via analytics cookies where you have provided consent.
• Engagement data: during advisory and facilitation work, we may hold notes, written outputs, and communications that contain information you share with us. This data is held under confidentiality and used solely to deliver the agreed services.

We do not collect sensitive personal data (health, financial, or biometric data) and do not ask for it.

3. Legal Basis for Processing

We process personal data on the following legal bases under Thailand's Personal Data Protection Act B.E. 2562 (PDPA):

• Consent: where you have provided explicit consent, for example by accepting analytics cookies or subscribing to updates.
• Contract performance: where processing is necessary to deliver advisory services you have engaged us to provide.
• Legitimate interests: where processing is reasonably necessary for our business operations, such as responding to enquiries, provided those interests do not override your rights.
• Legal obligation: where we are required to process data to comply with Thai law.

4. How We Use Your Data

• To respond to enquiries submitted through our contact form.
• To deliver advisory, facilitation, and concept shaping services you have commissioned.
• To send written session notes and deliverables to clients.
• To improve our website based on anonymised analytics data.
• To meet applicable legal and regulatory requirements.

We do not use your personal data for automated decision-making or profiling. We do not sell personal data to third parties.

5. Data Sharing

We do not share personal data with third parties except in the following circumstances:

• Service providers: we use third-party tools (such as email hosting and website analytics platforms) that may process data on our behalf. These providers are selected for their privacy standards and operate under appropriate data processing agreements.
• Legal requirements: where we are required to disclose data to comply with Thai law, a court order, or regulatory authority.

Client engagement data — notes, briefs, and correspondence — is never shared with other clients or third parties outside the terms of the relevant engagement agreement.

6. Data Retention

• Contact enquiries: retained for up to 24 months unless an ongoing engagement is established.
• Client engagement records: retained for up to 5 years following the conclusion of an engagement, in line with standard business record-keeping practice.
• Analytics data: retained in anonymised or aggregated form; individual session data typically expires after 14 months.
• Cookie consent records: retained for 12 months.

7. Data Protection Measures

We take reasonable technical and organisational measures to protect personal data from unauthorised access, loss, or misuse. These include:

• HTTPS encryption for all data transmitted through this website.
• Access to client data restricted to Nimano team members with a need to know.
• Regular review of data held and deletion of data no longer needed.
• Use of reputable, security-reviewed third-party services for email and document storage.

In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and the relevant supervisory authority as required under the PDPA.

8. Cookies

Our website uses cookies to support basic functionality and, where you consent, to collect analytics data. Detailed information about the cookies we use, their purpose, and how to manage them is available in our Cookie Policy.

9. Your Rights Under the PDPA

Under Thailand's Personal Data Protection Act, you have the following rights with respect to your personal data:

• Right to access: to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate or incomplete data.
• Right to erasure: to request deletion of your data where there is no overriding legal basis to retain it.
• Right to restrict processing: to request that we limit how we use your data in certain circumstances.
• Right to data portability: to receive a copy of your data in a structured, commonly used format.
• Right to object: to object to processing based on legitimate interests.
• Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) in Thailand if you believe your rights have not been upheld.

10. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies separately.

11. Children's Privacy

Our services are directed at business professionals and are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data through our site, please contact us and we will promptly remove it.

12. Changes to This Policy

We may update this policy from time to time. Where changes are material, we will note the updated date at the top of this page. Continued use of our website following an update constitutes acceptance of the revised policy.

13. Contact for Data Enquiries

For any questions about this privacy policy or your personal data, contact us at: