Personal data processing policy

1. General provisions

This Personal Data Processing Policy defines the procedure for processing and protecting personal data of users of the site `https://prohuahin.com/` and its subdomains.

The operator of personal data is `Prohuahin Co., Ltd`, registered with the `Provincial Partnership and Company Registration Office, Prachuap Khiri Khan, Department of Business Development, Ministry of Commerce, Thailand`.

This Policy applies to personal data that the Operator receives when using the site, including:

  • sending applications and appeals;

  • registration and login to your personal account;

  • use of favorites, collections and other user services;

  • use of the site and its technical services.


The operator processes personal data in accordance with applicable law. Since the site is aimed, among other things, at users from the Russian Federation, and the infrastructure used is located in the Russian Federation, when processing data, the applicable requirements of the legislation of the Russian Federation are taken into account to the extent that they are subject to application.

2. Terms

The following terms are used in this Policy:- `Operator` - `Prohuahin Co., Ltd`, which independently or jointly with other persons organizes and carries out the processing of personal data.

  • `Site` - site `https://prohuahin.com/` and its subdomains.

  • `User` - an individual using the Site.

  • `Personal data` - any information relating directly or indirectly to a specific or identifiable individual.

  • `Processing` - any action or set of actions with personal data performed using automation tools or without their use.


3. What data can be processed

Depending on the scenario for using the Site, the Operator may process the following categories of data:

3.1. Data that the User provides independently

  • last name, first name, patronymic or full name;

  • telephone number;

  • email address;

  • username in the messenger;

  • text of the appeal, application or message;

  • other information that the User voluntarily provides in forms on the Site.


3.2. Account and personal account information

  • email address;

  • name specified during registration;

  • account identifiers;

  • information about roles and access rights within the Site services;

  • information posted by the User in his personal account, including data on applications, selected objects and related user actions.


3.3. Technical and behavioral data- cookies;
  • technical session identifiers;

  • data on actions on the Site, including information about pages visited, objects viewed and referral source;

  • information about the browser, device, operating system, language, date and time of access;

  • `IP address` and other technical data that can be recorded by the server infrastructure, security, logging, access restriction and security tools.


The Operator should not receive special categories of personal data from the User, unless otherwise expressly required by law or a separate service of the Site.

4. Purposes of processing personal data

The operator processes personal data for the following purposes:

4.1. Processing requests, requests and maintaining communication

For this purpose the following may be processed:

  • name;

  • telephone;

  • email address;

  • username in the messenger;

  • text of the appeal;

  • information about the property of interest.


4.2. Registration, authentication and provision of access to your personal account

For this purpose the following may be processed:

  • email address;

  • Name;

  • account details;

  • technical authorization identifiers;

  • information about access rights and actions in the account.


4.3. Providing site functionality

For this purpose the following may be processed:- data about selected objects;

  • data on user selections and applications;

  • information about the User’s actions on the Site;

  • technical identifiers necessary for the correct operation of interfaces and user sessions.


4.4. Analytics, website development and ensuring its performance

For this purpose the following may be processed:

  • cookies;

  • technical data on the use of the site;

  • data on views of pages and objects;

  • `IP address`, information about the browser, device and referral source;

  • other data necessary for diagnosing errors, protecting the Site and analyzing the use of services.


4.5. Fulfillment of obligations provided for by law and protection of the rights of the Operator

The operator may process personal data to the extent necessary for:

  • compliance with mandatory legal requirements;

  • consideration of requests and appeals from competent authorities;

  • preventing abuse, fraud and other illegal actions;

  • protection of the rights and legitimate interests of the Operator, Users and third parties.


5. Legal grounds for processing

The operator processes personal data on the following grounds:- the User’s consent to the processing of personal data;

  • the need for processing for the conclusion and execution of an agreement or the provision of functionality of the Site at the request of the User;

  • the need to fulfill the obligations assigned to the Operator by law;

  • the legitimate interests of the Operator in terms of ensuring the performance, security, development and protection of the Site, if such interests do not violate the rights and freedoms of the User.


6. Processing methods

The operator can perform the following actions with personal data:

  • collection;

  • recording;

  • systematization;

  • accumulation;

  • storage;

  • clarification;

  • extraction;

  • usage;

  • transmission;

  • depersonalization;

  • blocking;

  • removal;

  • destruction.


Processing is carried out both with the use of automation tools and without their use, if this is necessary to achieve the stated goals.

7. Transfer of data to third parties

The Operator has the right to transfer personal data to third parties or entrust processing to the extent necessary for the operation of the Site and the achievement of the goals specified in this Policy.

These individuals and services may include:- hosting and infrastructure providers;

  • contractors providing support for the site, servers, databases and storage systems;

  • messaging and notification services, including `Telegram`, if necessary for processing applications and internal notifications;

  • cartographic and geoservices, including `Google Maps` and geocoding services;

  • analytical services, if they are used on the Site;

  • state bodies and other authorized organizations - in cases provided for by law.


If a particular service requires additional information or consent of the User, the Operator provides such information in the Site interface or in additional documents.

8. Cross-border transfer of personal data

Taking into account the structure of the Operator's business and the nature of the activities related to real estate in Thailand, personal data may be processed both in the Russian Federation and abroad, including the Kingdom of Thailand, if necessary to achieve the purposes of processing.

When transferring cross-border, the Operator takes reasonable measures to ensure the confidentiality and protection of personal data, and also takes into account the requirements of applicable law.

9. Storage of personal data

Personal data is stored no longer than required by the purposes of processing, unless a different period is established by law, contract or mandatory requirements for storing information.The Operator uses server and technical infrastructure located in the Russian Federation, and may also use other technical means and services if necessary for the operation of the Site and for legitimate processing purposes.

Specific storage periods for individual categories of data are determined by the Operator’s internal documents, the purpose of the corresponding service, legal requirements and the need to protect the Operator’s rights.

10. Cookies and similar technologies

The site may use:

  • mandatory cookies and local technical browser storage necessary for the operation of the Site, authorization and saving user settings;

  • analytical cookies and other technologies to collect information about the use of the Site;

  • technical session identifiers and other similar means.


The user can change browser settings and limit the use of cookies. In this case, certain functions of the Site may not work correctly or become unavailable.

11. Measures to protect personal data

The operator takes the necessary legal, organizational and technical measures to protect personal data, including:

  • restriction of access to data;

  • application of information security tools;

  • use of authentication mechanisms and access rights delimitation;

  • data backup and recovery;

  • monitoring of security events and logging of technical events;

  • internal control measures and response to incidents.## 12. Rights of the subject of personal data


The user has the right:

  • receive information about the processing of your personal data;

  • demand clarification, blocking or deletion of personal data if it is incomplete, outdated, inaccurate, illegally obtained or not needed for the stated purposes;

  • withdraw consent to the processing of personal data if the processing is based on consent;

  • object to processing in cases provided for by applicable law;

  • contact the Operator regarding the processing of personal data;

  • protect your rights and legitimate interests in ways provided for by law.


13. Procedure

For questions regarding the processing of personal data, the User can contact the Operator at the email address: `info@prohuahin.com`.

It is recommended to indicate in your application:

  • name and contact information for feedback;

  • description of the request;

  • information that allows you to identify the User in the Operator’s system, if this is necessary for a response.


The operator considers requests within a reasonable time, taking into account the nature of the request and the requirements of applicable law.

14. Change of Policy

The operator has the right to make changes to this Policy.

The new edition of the Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new edition.

15. Operator contact details- Name: `Prohuahin Co., Ltd`
  • Email: `info@prohuahin.com`

  • Notification address: `[TBD]`

  • Contact person for questions of personal data: `[TBD]`