Privacy Policy

1. Introduction

Clearpath ("we", "us", "our") is committed to handling personal information responsibly. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it.

This policy applies to information collected through our website at clearpathx.biz, through our session booking process, and through any other direct communication with us. Please read it carefully. If you have questions, contact us at [email protected].

Clearpath is based at 90 Silom Road, Bang Rak, Bangkok 10500, Thailand, and operates under Thai law, including the Personal Data Protection Act B.E. 2562 (2019) (PDPA).

2. Data We Collect

Information you provide directly

• Full name and email address (required when submitting an enquiry)
• Phone number (optional, if provided in your enquiry)
• Any message content you include in an enquiry form
• Session preferences or questions you communicate to us

Information collected automatically

• Cookies and similar tracking technologies (see our Cookie Policy)
• Standard web server logs (IP address, browser type, pages visited, timestamp)
• Analytics data if analytics cookies are accepted

Legal basis for processing

We process your data on the following bases: (a) your consent, given when you submit an enquiry form or accept cookies; (b) our legitimate interest in responding to enquiries and improving our services; and (c) performance of a contract, where you have booked a session.

3. How We Use Your Data

• To respond to your enquiry and describe suitable session options
• To confirm and manage session bookings
• To send session-related materials (checklists, reference notes) where relevant
• To send update notifications to library members, where applicable
• To improve our website and session content based on aggregated usage data
• To comply with applicable legal obligations

We do not use your personal data for automated decision-making or profiling.

4. Data Sharing

We do not sell, rent, or share your personal data with third parties for marketing purposes. We may share data with:

• Our website hosting and email service providers, who process data on our behalf under data processing agreements
• Analytics providers, where you have consented to analytics cookies
• Law enforcement or regulatory bodies, where required by law

All third-party processors we use are required to handle your data in accordance with applicable data protection law.

5. Data Retention

Enquiry data is retained for up to 24 months from the date of last contact, or for the duration of an active session relationship. Session booking records are retained for up to three years for administrative purposes. You may request deletion of your data at any time (see Section 7).

6. Data Security

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

• TLS encryption for all data transmitted through our website
• Access controls restricting data access to authorised staff only
• Regular review of data handling procedures

In the event of a personal data breach, we will notify affected individuals and the relevant authorities in accordance with our legal obligations under the Thai PDPA.

7. Your Rights

Under the Thai Personal Data Protection Act (PDPA), you have the following rights in relation to your personal data:

• Right to access: request a copy of the personal data we hold about you
• Right to rectification: request correction of inaccurate or incomplete data
• Right to erasure: request deletion of your personal data in certain circumstances
• Right to restrict processing: request that we limit how we use your data
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interests
• Right to withdraw consent: withdraw consent for processing at any time, without affecting the lawfulness of prior processing

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

If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Committee of Thailand.

8. Cookies

We use cookies to support website functionality and, with your consent, to collect analytics data. Full details are set out in our Cookie Policy. You can manage your cookie preferences at any time through that page.

9. 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 own privacy policies before submitting personal data.

10. Children's Privacy

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently received data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Continued use of our website after changes are published constitutes acceptance of the updated policy. For significant changes, we will notify active correspondents by email where possible.

12. Contact

For any privacy-related questions or to exercise your rights:

• Email: [email protected]
• Post: Clearpath, 90 Silom Road, Bang Rak, Bangkok 10500, Thailand