Privacy Policy – Smart Living TH

Privacy Policy

Effective Date: 1 January 2025 | Last Updated: 1 January 2025

This Privacy Policy describes how Smart Living TH (legal name: JAI SHREE LAXMI KUBER LLC, hereinafter referred to as “we”, “us”, or “our”) collects, uses, discloses, and protects your personal data when you visit or interact with our website at tomorrowlthailand.digital (the “Website”). We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner.

This Policy is prepared and enforced in accordance with the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) of Thailand, as well as any subordinate regulations, notifications, and guidelines issued by the Office of the Personal Data Protection Committee (“PDPC”). Where applicable, we also acknowledge principles consistent with international best practices in data protection.

By accessing or using our Website, submitting any form, or otherwise providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue your use of our Website.

1. Identity and Contact Details of the Data Controller

The Data Controller responsible for your personal data is:

Company Name: Smart Living TH
Legal Name: JAI SHREE LAXMI KUBER LLC
Website: tomorrowlthailand.digital
Registered Address: 4141 Philips Hwy, Jacksonville, Florida, 32207-6836, United States
Telephone: +13149314876
Email: [email protected]

If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us using the details provided above or refer to Section 13 of this Policy for dedicated privacy inquiry contact information.

2. Personal Data We Collect

We collect personal data only to the extent necessary for the purposes described in this Policy. The categories of personal data we collect include:

2.1 Data You Provide Directly

When you submit an enquiry or contact form on our Website, you may provide us with the following information:

Full Name: To identify you and personalise our response.
Email Address: To respond to your enquiry and communicate with you.
Telephone Number: To contact you by phone if necessary or if you request a callback.
Message / Enquiry Content: The content of your message, question, or request submitted through our contact form.

You are not required to provide all of the above fields; however, failure to provide certain information (such as a contact email address) may prevent us from responding to your enquiry.

2.2 Data Collected Automatically

When you visit our Website, certain technical and usage data may be collected automatically by our web servers or third-party tools, including:

IP Address: For security and fraud prevention purposes.
Browser Type and Version: To ensure compatibility and optimise user experience.
Operating System: For technical diagnostics.
Pages Visited and Navigation Paths: To understand how users interact with our Website.
Date and Time of Access: For server log and security purposes.
Referral URL: The page or link that directed you to our Website.
Device Identifiers: Including screen resolution and device type.

This automatically collected data is generally non-identifying on its own, but may be combined with other information to identify you in certain circumstances.

2.3 Cookie Data

We use cookies and similar tracking technologies on our Website. Full details are provided in Section 5 of this Policy.

3. Legal Basis for Processing Your Personal Data

Under the PDPA, we must have a lawful basis for collecting and processing your personal data. Depending on the purpose, we rely on one or more of the following legal bases:

Consent (Section 19 PDPA): Where you have given us clear, informed, and freely given consent to process your data for a specific purpose, such as subscribing to marketing communications or accepting optional analytics cookies.
Legitimate Interests (Section 24(5) PDPA): Where processing is necessary for our legitimate business interests, such as responding to contact form enquiries, improving our Website, and maintaining the security of our systems — provided these interests do not override your fundamental rights and freedoms.
Contractual Necessity (Section 24(3) PDPA): Where processing is necessary to take steps at your request prior to entering into a contract, or to perform a contract to which you are a party.
Legal Obligation (Section 24(6) PDPA): Where we are required to process your data to comply with a legal obligation under Thai law.

4. How We Use Your Personal Data

We use the personal data we collect for the following specific purposes:

Responding to Enquiries: To read, process, and respond to contact form submissions and general enquiries sent to us via the Website.
Customer Service and Support: To provide you with assistance, answer questions, and follow up on your requests.
Internal Record Keeping: To maintain accurate records of communications and enquiries for operational and legal purposes.
Website Improvement and Analytics: To analyse how visitors use our Website so that we can improve content, design, and functionality. This is carried out only where you have consented to analytics cookies or where permitted under our legitimate interests.
Security and Fraud Prevention: To monitor for and protect against suspicious activity, cyberattacks, and unauthorised access to our systems.
Legal Compliance: To comply with applicable Thai laws, regulations, court orders, and governmental authority requests.
Marketing Communications (if applicable): We will only send you marketing or promotional communications if you have provided explicit consent. You may withdraw such consent at any time by contacting us at [email protected].

We will not use your personal data for purposes that are incompatible with those disclosed in this Policy without informing you and, where required, obtaining your consent.

5. Cookies and Similar Technologies

Our Website uses cookies — small text files stored on your device — and similar tracking technologies to help us operate and improve the Website. In accordance with the PDPA and best practices, we categorise cookies as follows:

5.1 Strictly Necessary / Functional Cookies

These cookies are essential for the Website to function correctly. They enable core features such as page navigation, security, and form functionality. These cookies do not require your consent under Thai law, as they are technically indispensable.

Session management cookies
Security tokens to prevent cross-site request forgery (CSRF)
Cookies that remember your cookie consent preferences

5.2 Analytics Cookies (Optional)

With your consent, we may use analytics cookies to collect anonymous, aggregated data about how visitors navigate and use our Website. This helps us understand user behaviour and make improvements. These cookies are activated only upon your informed consent via our cookie consent banner.

Page view tracking
Time spent on page
Traffic source analysis
Device and browser breakdown

You may withdraw your consent to analytics cookies at any time by adjusting your cookie preferences through the cookie settings panel available on our Website, or by configuring your browser to block cookies. Please note that disabling certain cookies may affect the functionality of the Website.

5.3 Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. To find out more about cookies and how to manage them, please visit www.allaboutcookies.org. Disabling strictly necessary cookies may impair your ability to use certain features of our Website.

6. Third-Party Services and Disclosures

We engage certain third-party services to operate and maintain our Website. These third parties may process personal data on our behalf or independently. We take reasonable steps to ensure that these third parties handle your data in compliance with applicable law.

6.1 Google Fonts

Our Website uses Google Fonts, a web font service provided by Google LLC (USA). When you visit our Website, your browser may make requests to Google’s servers to load font files. This may result in Google receiving your IP address and browser information. Google Fonts is served from fonts.googleapis.com and fonts.gstatic.com. For more information on how Google handles this data, please refer to Google’s Privacy Policy at https://policies.google.com/privacy.

6.2 Tailwind CSS CDN

Our Website loads the Tailwind CSS framework from a Content Delivery Network (CDN). CDN requests may log your IP address and browser information for the purpose of delivering stylesheet resources. No personal data is intentionally transmitted beyond what your browser sends as part of a standard HTTP request.

6.3 Web Hosting and Server Providers

Our Website is hosted on servers managed by a third-party hosting provider. Your data, including form submissions and server logs, may be stored on servers that could be located within or outside of Thailand. We select hosting providers that maintain appropriate security standards and, where applicable, data processing agreements.

6.4 Email Service Providers

Contact form submissions may be transmitted and stored via third-party email or form processing services. We ensure such providers are bound by appropriate contractual data protection obligations.

6.5 Legal and Regulatory Disclosures

We may disclose your personal data to competent authorities, courts, or government agencies if required to do so by law, court order, or regulatory directive issued under Thai law, without prior notice to you where legally permitted.

We do not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes.

7. International Transfers of Personal Data

As described in Section 6, some of our third-party service providers — including Google LLC (Google Fonts) — are based outside of Thailand, and as a result, your personal data may be transferred to, stored in, or processed in countries outside Thailand, including but not limited to the United States.

Under Section 28 of the PDPA, transfers of personal data to foreign countries are permissible only if the destination country has adequate personal data protection standards, or if appropriate safeguards are in place. Where such transfers occur, we take one or more of the following measures to ensure adequate protection:

Relying on standard contractual clauses or data processing agreements with the recipient;
Ensuring the recipient is certified under a recognised international data protection framework;
Transferring only the minimum necessary data for the stated purpose;
Obtaining your explicit consent where required by the PDPC.

By using our Website (including interacting with services such as Google Fonts), you acknowledge that your data may be transferred internationally as described above.

8. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Thai law. Our standard retention periods are as follows:

Contact Form Submissions (name, email, phone, message): Retained for a period of 3 years from the date of submission, in order to maintain records of enquiries and potential pre-contractual communications, or as required by Thai civil and commercial law.
Server Access Logs (IP address, browser data): Retained for a maximum of 90 days for security and diagnostic purposes.
Analytics Data (if consent is given): Retained in aggregated, anonymised form for up to 26 months, in line with industry standard analytics retention periods.
Consent Records: Records of your consent (including cookie consent) are retained for as long as the consent is valid and for a reasonable period thereafter to demonstrate compliance.

After the applicable retention period expires, your personal data will be securely deleted, destroyed, or anonymised in a manner that prevents recovery or re-identification.

9. Data Security Measures

We are committed to protecting your personal data against unauthorised access, disclosure, alteration, or destruction. We implement a range of technical and organisational security measures, including:

Encryption: Our Website uses HTTPS (SSL/TLS) encryption to protect data in transit between your browser and our servers.
Access Controls: Access to personal data stored in our systems is restricted to authorised personnel who have a legitimate need to access it in the course of their duties.
Secure Form Processing: Contact form submissions are transmitted securely and stored with appropriate access restrictions.
Regular Security Reviews: We periodically review our security practices and update our technical measures to address emerging threats.
Vendor Due Diligence: We assess the security practices of third-party service providers before engaging them and require appropriate contractual commitments.
Data Minimisation: We collect only the minimum personal data necessary for each specific purpose.

While we make every reasonable effort to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security and encourage you to take your own precautions when submitting data online.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the PDPC and, where required, affected individuals, in accordance with Section 37 of the PDPA within 72 hours of becoming aware of the breach.

10. Your Rights as a Data Subject

Under the Personal Data Protection Act B.E. 2562 (2019), you have the following rights in relation to your personal data. We are committed to facilitating the exercise of these rights in a timely and transparent manner:

Right to be Informed (Section 23): You have the right to receive clear and transparent information about how your personal data is collected and used. This Privacy Policy fulfils that obligation.
Right of Access (Section 30): You have the right to request access to the personal data we hold about you, and to receive a copy of that data in a commonly used format.
Right to Rectification (Section 35): You have the right to request that we correct any inaccurate, incomplete, or misleading personal data we hold about you.
Right to Erasure / Right to be Forgotten (Section 33): You have the right to request the deletion or destruction of your personal data when it is no longer necessary for the purpose for which it was collected, when you withdraw consent (where consent was the legal basis), or where the data has been unlawfully processed.
Right to Restriction of Processing (Section 34): You have the right to request that we restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of the data or while your objection is assessed.
Right to Data Portability (Section 31): Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that we transmit that data to another data controller where technically feasible.
Right to Object (Section 32): You have the right to object to the processing of your personal data where processing is based on legitimate interests, including objecting to direct marketing at any time.
Right to Withdraw Consent (Section 19): Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) if you believe we have processed your personal data in violation of the PDPA. The PDPC can be contacted at: www.pdpc.go.th.

To exercise any of the above rights, please submit a written request to us at [email protected] or to our address at 4141 Philips Hwy, Jacksonville, Florida, 32207-6836, United States. We will respond to your request within 30 days of receipt. We may need to verify your identity before processing your request. In some cases, we may be required or entitled to refuse or limit your request under applicable law, and we will explain the reason for any such refusal.

11. Children’s Privacy

Our Website and services are not directed at or intended for use by children under the age of 20 years. Under Thai law, minors under the age of 20 require parental or guardian consent to enter into legal agreements and to consent to data processing.

We do not knowingly collect personal data from children under 20 without verifiable parental consent. If you believe that a child under the age of 20 has submitted personal data to us without appropriate consent, please contact us immediately at [email protected] and we will take prompt steps to delete such data from our records.

If you are under 20 years of age, please do not submit any personal data to us through this Website without the involvement and consent of your parent or legal guardian.

12. Links to Third-Party Websites

Our Website may contain hyperlinks to third-party websites, social media platforms, or external resources. This Privacy Policy applies solely to our Website and our processing of your personal data. We have no control over, and take no responsibility for, the privacy practices or content of any third-party website. We encourage you to read the privacy policies of any third-party website you visit.

The inclusion of a link to a third-party website does not imply our endorsement of that website or its operator.

13. Contact for Privacy Inquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our designated privacy point of contact:

Organisation: Smart Living TH (JAI SHREE LAXMI KUBER LLC)
Email: [email protected]
Telephone: +13149314876
Postal Address: 4141 Philips Hwy, Jacksonville, Florida, 32207-6836, United States
Website: tomorrowlthailand.digital

We aim to acknowledge all privacy-related enquiries within 5 business days and to provide a full response within 30 calendar days. For complex requests, we may extend this period by a further 30 days, in which case we will inform you of the extension and the reasons for it.

If you are dissatisfied with our response or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand:

Office of the Personal Data Protection Committee (PDPC)
Website: www.pdpc.go.th

14. Thailand PDPA Compliance Statement

Smart Living TH is committed to full compliance with the Personal Data Protection Act B.E. 2562 (2019) (PDPA) of Thailand and all subsidiary regulations, ministerial regulations, and PDPC guidelines issued thereunder. Our compliance programme includes:

Maintaining a Record of Processing Activities (ROPA) as required for Data Controllers;
Implementing appropriate technical and organisational data security measures;
Training our personnel on data protection obligations under Thai law;
Conducting data protection assessments for higher-risk processing activities;
Reviewing and updating our privacy practices in response to changes in law or PDPC guidance;
Ensuring that consent records are maintained and that data subjects can exercise their rights effectively.

We recognise that data protection is an ongoing obligation and we actively monitor developments in Thai and international data protection law to ensure our practices remain current and compliant.

15. Changes to This Privacy Policy

We reserve the right to update, amend, or modify this Privacy Policy at any time in response to changes in applicable law, our business practices, or the services we offer. Any changes will take effect from the date the revised Policy is published on our Website.

Where changes are material — meaning they significantly affect how we process your personal data or your rights as a data subject — we will take reasonable steps to notify you in advance. Such notification may include:

Displaying a prominent notice on our Website homepage or contact page;
Sending an email notification to individuals who have previously provided us with their email address (where technically feasible and where we hold your contact details);
Updating the “Last Updated” date at the top of this Policy.

We encourage you to review this Privacy Policy periodically to remain informed about how we protect your data. Your continued use of the Website after any changes to this Policy constitutes your acknowledgement of the updated terms.

If you disagree with any changes to this Policy, you should cease using our Website and, if applicable, contact us to exercise your data subject rights.

16. Governing Law and Jurisdiction

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Kingdom of Thailand. Any dispute, claim, or matter arising in connection with this Privacy Policy or the processing of personal data by Smart Living TH shall be subject to the exclusive jurisdiction of the competent courts of Thailand.

In the event of any inconsistency between the English-language version of this Privacy Policy and any translated version, the English version shall prevail to the extent permitted by law.