Privacy Policy

Last updated: 1 January 2025

FrameIndex Co., Ltd. (“Company”, “we”, “us”) is committed to protecting your personal data. This policy explains how we collect, use, and disclose your personal data, and your rights under the Thai Personal Data Protection Act B.E. 2562 (PDPA) and applicable data-protection laws including the EU General Data Protection Regulation (GDPR) where relevant.

1. Data We Collect

We collect personal data directly from you when you register or use our services:

Identity data

• Full name
• LINE account (LINE User ID, display name, profile photo)

Contact data

• Mobile phone number
• Email address

Transaction data

• Purchase history, invoices, and payment status
• Information necessary to process your transactions (we do not store card details directly — payment processing is handled by certified payment providers)

Technical and usage data (only with your consent)

• Meta Pixel cookie (_fbp) and Facebook click ID (fbclid) — used to measure the effectiveness of Facebook/Instagram advertising
• Hashed IP address and browser data transmitted to Meta Conversions API to verify transactions
• Anonymous session identifier stored in browser session memory (not persisted across sessions)

2. Purposes and Legal Bases

Purpose	Legal basis
Provide customer services, manage orders, invoices, and inventory	Performance of contract (PDPA Art. 24(3) / GDPR Art. 6(1)(b))
Send payment reminders and after-sales service notifications	Performance of contract
Improve and analyse service performance	Legitimate interests (PDPA Art. 24(5) / GDPR Art. 6(1)(f))
Measure and deliver relevant advertising on Facebook/Instagram via Meta Pixel and Meta Conversions API	Consent (PDPA Art. 19 / GDPR Art. 6(1)(a))
Comply with legal obligations	Legal obligation (PDPA Art. 24(6) / GDPR Art. 6(1)(c))

3. Data Sharing

We may share your personal data with:

• Payment processors (KBank / Beam Checkout) — to process payments securely
• Meta Platforms, Inc. — hashed data only (email, phone, IP) via Meta Conversions API, and only when you have given consent for advertising measurement
• LINE Corporation — to link your account via LINE Login, subject to LINE's own Terms and Privacy Policy
• ERP system provider (Odoo) — to manage orders, inventory, and customer records within our company
• Competent legal authorities — when required by law

We do not sell your personal data to third parties for their own marketing purposes.

4. Data Retention

• Account data and purchase history — for the duration of your customer relationship and 3 years after the last transaction
• Consent records — until you withdraw consent or as required by law
• Meta Pixel and Conversions API data — subject to Meta's own retention policies (generally up to 180 days)
• Financial transaction records — 5 years as required by Thai law

5. Your Rights

Under PDPA (Thailand) and GDPR (where applicable) you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate data
• Erasure — request deletion of data no longer necessary for its original purpose
• Data portability — receive your data in a machine-readable format
• Object — object to processing based on legitimate interests
• Withdraw consent — withdraw consent for advertising tracking at any time through your customer portal (withdrawal does not affect prior processing)
• Lodge a complaint — with the Personal Data Protection Committee (PDPC) in Thailand, or your national data-protection authority if you are in the EU/EEA

To exercise these rights, contact us at jirawat.z@frameindex.com. We will respond within 30 days.

6. Cookies and Tracking

When you access our customer portal or website and give consent, we use:

• Meta Pixel — a tracking script from Meta Platforms that records PageView and purchase events to measure advertising performance
• _fbp cookie — set by Meta Pixel to identify your browser for ad attribution; expires after 90 days
• Meta Conversions API — sends hashed transaction data from our server directly to Meta to reduce reliance on cookies and improve measurement accuracy. Data is hashed using SHA-256 before transmission and is never shared in plain text

You may withdraw consent for tracking at any time from your customer portal or by emailing jirawat.z@frameindex.com

7. International Transfers

Some of our service providers (Meta, LINE) process data in countries outside Thailand and the EU. We rely on Standard Contractual Clauses and equivalent safeguards to ensure your data remains protected to the same standard as required by PDPA and GDPR.

8. Security

We implement appropriate technical and organisational measures including HTTPS encryption, SHA-256 hashing of identity data before transmission to third parties, and role-based access controls.

9. Contact

If you have concerns about our handling of your personal data, please contact us first. If you are not satisfied with our response, you may contact the Thai Personal Data Protection Committee (PDPC) at https://www.pdpc.or.th