Brickpaths Brokerage Group Co., Ltd. established and registered in accordance with the laws of Thailand, with its headquarters located at 76 Soi Sukhumvit 101/2, Sukhumvit Road, Bang Na Nuea Subdistrict, Bang Na District, Bangkok 10260, Thailand (hereinafter referred to as "the Company/Brickpaths/We"), places great importance on the protection of personal data. As a data controller under the Personal Data Protection Act B.E. 2562 ("PDPA"), we have a legal duty to inform you through this document of the reasons and methods by which we collect, use, or disclose your personal data, as well as to inform you of your rights as a data subject.
This Privacy Policy ("Policy") outlines the basis on which Brickpaths may collect, use, disclose, or process your personal data when you use our services and when you access our website at www.brickpaths.com ("Website") in accordance with the PDPA.
This Privacy Policy includes and describes important information, including:
(a) Personal data we collect from you (b) Sources of personal data (c) How we process personal data (d) Purposes for collecting, using, and disclosing personal data (e) Disclosure or sharing of personal data (f) Retention period for personal data (g) Measures for storing and processing personal data (h) Rights of the data subject.
We inform you that this Policy may be amended from time to time to comply with legal requirements. Any changes will be published on our website. We recommend that you review this Policy regularly. If any part of this Privacy Policy is unsuitable for you, we advise you to refrain from using our products, services, and website. This Policy is an integral part of our Terms of Use, which you can access [here](insert link to Terms of Use).
Brickpaths is a brokerage and advisory firm specializing in the buying, selling, and leasing of real estate.
We collect your personal data from various sources as detailed below:
2.1 Data collected directly and indirectly: We collect your personal data both directly, through the information you provide during registration or when using our services on the website, and indirectly from your usage experience, which is automatically recorded during your use of our services.
2.2 Types of data collected: The personal data we collect can be categorized into two types: identifiable personal data and non-identifiable data.
3.1 We collect the information you voluntarily provide when you: Set up an account or register to receive specific offers, Complete and submit web forms or contact us in any way, Participate in our surveys or promotional activities, Register for events we organize, Or share details about your property interests and preferences (e.g., your criteria for new property searches). The types of personal data we generally collect include: Contact and personal profile information: This includes your full name, residential or work address, email, and other contact methods, along with any personal details you share or post, such as demographics, preferences, or other information provided through your account.
3.2 Property and real estate information: We collect information related to property transactions, sales, and past and current listings (such as property location, value, photos, and specific details). This also includes additional details you may provide, such as your property search preferences, intention to buy or sell property, criteria and preferences for home searches, language preferences, household member details, property financing information, co-ownership details, and other relevant information
3.3 Transaction and payment details: In some cases, we collect details about purchases and payments to process transactions with you. This may include your credit card number, direct deposit or financial account details, billing address, and other relevant account information.
3.4 Social media login information: We offer the option to register using your social media account. If you choose to register this way, we will collect personal information such as your name, address, and email linked to your social media account, depending on your privacy settings.
3.5 Personal Data Automatically Provided Through Your Use of Our Website:
When you visit our services, we collect data sent to us by your computer, mobile phone, or other access devices, which includes:
Analytics Data: We use third-party service providers such as Google Analytics to collect and analyze data about your use of the website and services, which helps us improve our offerings. For more information on how Google uses data, you can visit How Google Uses Data.
Data from Third-Party Sources: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data. This additional information helps us verify the data you have provided to Brickpaths and enhances our ability to provide relevant information about our business, products, and services.
We collect your personal data from the following sources:
Personal data obtained directly from you, either in person or through online channels, including:
We will process your personal data within the scope defined by the Personal Data Protection Act (PDPA) and collect only the data necessary for such operations. Additionally, we may use, collect, and process your personal data for the various purposes outlined below ("Purposes"). We have summarized the use of your personal data along with explaining the lawful basis of processing as follows:
5.1 In relation to our services
| Purpose | Legal Basis |
|---|---|
| For the purpose of providing services, managing accounts, and processing orders | Contractual basic Legitimate interest basis |
| For the purpose of managing your relationship with us and/or providing related services to you as a service recipient | Contractual basic Legitimate interest basis |
| For the purpose of collecting customer statistics to improve the quality of our services | Legitimate interest basis |
| For the purpose of managing our website | Legitimate interest basis |
| For the purpose of investigating and preventing fraud and other criminal activities, including reporting to the police | Legal obligation basis Public interest basis Legitimate interest basis |
| For the purpose of auditing and resolving complaints | Contractual basis Legitimate interest basis |
5.2 In relation to the use of services through our website
| Purpose | Legal Basis |
|---|---|
| For the purpose of conducting data analysis | Contractual basic Legitimate interest basis |
| For the purpose of maintaining and improving system security | Legitimate interest basis |
| For the purpose of improving the efficiency of our services and managing our website | Legitimate interest basis |
Use of Personal Data At Brickpaths, we use your personal data to efficiently manage and handle interactions and relationships with us. Here’s how we may use your personal data:
Sharing of Personal Data
We may share your personal data under certain circumstances as described in this section and with specific third parties:
We require any external persons or entities to whom we disclose or share your personal data as mentioned above to maintain the confidentiality and protection of your personal data in accordance with the standards set by the Personal Data Protection Act B.E. 2562 (2019). They are only permitted to use your personal data for the purposes agreed upon between us and the external persons or entities. This is to prevent unauthorized disclosure of personal data and to prevent the use of your personal data beyond the agreed-upon purposes.
7.1 We will maintain your personal data using technical safeguards, administrative safeguards, and physical safeguards to ensure the confidentiality, integrity, and availability of personal data. These measures are designed to prevent unauthorized or unlawful access, collection, alteration, correction, use, and/or disclosure of personal data, in accordance with applicable laws.
7.2 We have monitoring systems in place to manage the destruction of personal data that is no longer necessary for our operations.
7.3 For sensitive personal data, we will implement additional security measures, including access control and usage management, backup systems, and emergency plans. We will also regularly assess and evaluate the risk of our systems.
However, while we make every effort to protect your personal data, we cannot guarantee the security of data transmitted through any online channel. Therefore, the transmission of data remains at your own risk.
Our Security Operations
Privacy and Security on the Internet
User Authentication: Users of Brickpaths' services are required to identify and verify their identity before accessing sensitive parts of our services. This is typically managed through the use of secure usernames and passwords.
Cookies and Tracking: More information about how we use cookies and other tracking technologies can be found in our Cookie Policy. This helps us understand how you use our website and enables us to provide better services.
Third-Party Services: Our website may include links to third-party websites, plugins, and applications. Clicking on these links may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we recommend that you read the privacy policies of the websites you visit.
To enhance your user experience more effectively, we use cookies to identify and track website users and access to our website, and to improve access to products or services tailored to your usage. Cookies are text files on your computer that are used to store details of your internet usage logs or your website visit behavior. We use cookies to store information about your website visits to help us provide better, faster, and more secure services when you use the website. We use cookies in the following cases:
9.1 Right to Access, Obtain Information or Copies: You have the right to access or obtain your personal data that is under our responsibility and request us to provide copies of such data. You can also request us to disclose how your personal data, which you did not consent to, was obtained.
9.2 Right to Data Portability: You have the right to receive your personal data in a format that is readable or usable by automated devices, and to use or disclose such data by automated means. You also have the right to request us to transmit or transfer your personal data in such a format to another data controller, where it is feasible by automated means.
9.3 Right to Object: You have the right to object to the collection, use, or disclosure of your personal data at any time if you suspect that the collection, use, or disclosure is contrary to the intended purpose or is unnecessary for the lawful interests of ours that you can reasonably expect, or for the performance of a task carried out in the public interest.
9.4 Right to Erasure or Destruction: You have the right to request the erasure or destruction of your personal data, or to anonymize it, if you believe that your personal data has been unlawfully collected, used, and/or disclosed, or if you consider that we no longer need to retain it for the relevant purposes specified in this policy, or if you have exercised your right to withdraw consent or your right to object as mentioned above.
9.5 Right to Restriction of Processing: You have the right to request the temporary suspension of the use of your personal data in cases where we are in the process of verifying your request to exercise your right to rectify or object to your personal data, or in any other cases where we are required by law to erase or destroy your personal data, but you request us to suspend the use instead.
9.6 Right to Rectification: You have the right to request the correction of your personal data to be accurate, up-to-date, complete, and not misleading.
9.7 Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant legal authority if you believe that the collection, use, and/or disclosure of your personal data is in violation of or does not comply with the relevant laws.
9.8 Right to Withdraw Consent: You have the right to withdraw your consent at any time while your personal data is with us, unless there are legal limitations or contractual obligations that benefit you.
The exercise of your rights as outlined above may be limited under applicable laws, and in certain cases, we may need to refuse or be unable to comply with your request to exercise these rights, such as complying with legal requirements or court orders, or for public interest reasons. Exercising your rights may infringe on the rights or freedoms of others. If we refuse your request, we will inform you of the reasons for the refusal.
11.1 We retain your personal data for as long as necessary to fulfill the purposes of providing our services and in accordance with the retention periods required by accounting standards, legal standards, and other relevant regulations. We will keep your personal data for a period of 10 years from the date the relationship between you and the company as a customer and business partner ends. However, in cases of disputes, the exercise of rights, or legal proceedings related to your personal data, the company reserves the right to retain that data until the dispute is resolved or a final judgment is rendered.
11.2 When determining the retention period, we consider the duration of our ongoing relationship with you and the provision of services. We retain your personal data as long as your account is active or as necessary to continue providing services, taking into account the nature of usage, the purposes of service provision, the sensitivity of personal data, the risks associated with misuse of personal data, and the retention periods required by applicable laws.
11.3 Your personal data obtained from cookies when you access our website will be retained for no more than ____ or as required by applicable law.
11.4 If we are required to comply with the law, court orders, or need to establish legal claims for any dispute resolution process, we may retain your personal data for the duration of the statutory limitation period or until the dispute is finally resolved, as the case may be.
To protect your personal data from unauthorized access, collection, use, disclosure, alteration, destruction, or similar risks, we implement appropriate administrative, physical, and technical safeguards, such as updating antivirus protection, encryption, and limiting the disclosure of personal data to authorized personnel within our organization and to third-party service providers, agents, or others only as necessary.
13.1 Global Operations: At Brickpaths, our operations extend globally, necessitating the transfer, storage, and processing of your personal data across international borders. By submitting your personal data to us, you agree to the transfer, processing, and storage of this data. We are committed to ensuring that your data is handled in accordance with this Privacy Policy and applicable data protection laws, regardless of where your data is accessed or stored.
13.2 Protecting Your Data: We are committed to protecting your personal data during international transfers by implementing measures such as:
We may assign or contract third parties (data processors) to process personal data on behalf of the company. Such third parties may provide services in various forms, such as hosting, outsourcing, or cloud computing services, or in other forms of contracting.
When assigning third parties to process personal data as data processors, we will establish agreements outlining the rights and responsibilities of the company as the data controller and those of the third party as the data processor. These agreements will specify the types of personal data that the company assigns for processing, including the purposes, scope of personal data processing, and other related agreements. The data processor is obligated to process personal data only within the scope defined in the agreement and according to the company's instructions, and is not permitted to process the data for other purposes.
We may review and modify this Privacy Policy in the future to improve personal data protection. We will notify you of any changes to this policy, and by continuing to use our services after any such modifications or updates, you accept those changes.
Brickpaths is not responsible for the voluntary disclosure of users’ personal data to others through our services. Users are advised to consider the sensitivity of any information they choose to share with others in public or private communications on our platform.
If you have any suggestions or inquiries regarding the collection, use, and/or disclosure of personal data, or if you wish to exercise your rights under this policy, you can contact us through the following channel:
Contact Information:
Email: support@brickpaths.com
422/33 Onnut Soi 17/16
Suan Luang, Suan Luang
Bangkok 10250, THAILAND
