Privacy Policy

1. Introduction

Suvarna Counsel is committed to handling personal data with discretion and in accordance with the Personal Data Protection Act B.E. 2562 (PDPA), which governs the collection, use, and disclosure of personal data in Thailand. This policy explains what data we collect, why we collect it, how long we retain it, and what your rights are in relation to it.

This policy covers data collected through our website at suvarnaa.sbs and through direct client engagement. It does not cover data processed by third-party services we may link to.

2. Data We Collect

We collect personal data in the following circumstances:

• Contact form submissions: name, email address, telephone number (optional), and the content of your message.
• Client engagement: identity documents, employment and contribution records, pension authority correspondence, and any other documents relevant to your legal matter.
• Website analytics: anonymised usage data (pages visited, session duration, device type) via cookies, if you have consented to analytics cookies.

3. Legal Basis for Processing

We process personal data on the following legal bases under the PDPA:

• Consent: for analytics cookies and marketing communications (where applicable).
• Contract performance: for data necessary to carry out the legal services you have engaged us for.
• Legitimate interests: for follow-up correspondence related to an enquiry you have made.
• Legal obligation: where we are required to retain data under Thai legal professional conduct rules or applicable legislation.

4. How We Use Your Data

• To respond to consultation enquiries submitted through our website or by telephone.
• To prepare and deliver the legal services described in your engagement letter.
• To correspond with pension authorities, courts, and administrative bodies on your behalf.
• To maintain records required by the Thai Lawyers Council Act and related professional obligations.
• To improve website performance through anonymised analytics (analytics cookies only, with consent).

We do not sell personal data. We do not use client data for marketing to third parties.

5. Data Sharing

We share personal data only in the following limited circumstances:

• Pension and administrative authorities: Social Security Office, Labour Court, administrative tribunals — where necessary to carry out your matter.
• Professional advisors: where an external specialist (e.g. a foreign pension authority liaison or accountant) is engaged with your knowledge and consent.
• Technology providers: our website hosting and analytics providers operate under contractual data processing agreements.
• Legal obligation: where required by court order or applicable Thai law.

6. Data Retention

• Client matter files: retained for 10 years from the conclusion of the engagement, in accordance with professional conduct obligations.
• Enquiry data (non-client): retained for 12 months from the date of the enquiry, then deleted.
• Website analytics data: retained for up to 14 months in anonymised form.

7. Cookies

Our website uses cookies. Essential cookies are required for basic site functionality. Analytics and preference cookies are optional and require your consent. Please see our Cookie Policy for full details.

8. Data Security

Client files are stored on password-protected, encrypted systems accessible only to authorised practice members. Physical documents are kept in locked storage at our Sukhumvit Road office. We do not transmit sensitive client documents via unencrypted email without prior client consent.

In the event of a personal data breach affecting your information, we will notify you and, where required, the relevant supervisory authority within 72 hours of becoming aware of the breach.

9. Your Rights Under the PDPA

As a data subject under Thai law, you have the following rights in relation to personal data we hold about you:

• Right of 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 data, subject to our legal retention obligations.
• Right to restriction: to request that we limit processing in certain circumstances.
• Right to data portability: to receive data in a structured, machine-readable format where processing is based on consent or contract.
• Right to object: to processing based on legitimate interests.
• Right to withdraw consent: at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

10. Supervisory Authority

If you believe your personal data has been handled incorrectly, you have the right to lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand, the relevant supervisory authority under the PDPA.

11. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies separately.

12. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe a minor has submitted data through our website, please contact us promptly.

13. Changes to This Policy

We may update this policy from time to time. Significant changes will be indicated by a revised "Last Updated" date. Continued use of our website or services following such changes constitutes acceptance of the revised policy.

14. Contact for Data Enquiries

For all data protection enquiries, please contact:

• Email: [email protected]
• Post: Suvarna Counsel, 47/12 Sukhumvit Road, Khlong Toei, Bangkok 10110, Thailand
• Telephone: +66 2 384 7261