Privacy Policy
Last Updated: 16 April 2025 · Effective: 16 April 2025
Introduction
Boon Capital ("we," "our," or "us") is committed to handling personal information responsibly. This policy explains what information we collect, how we use it, how long we retain it, and what rights you have in relation to it. It applies to people who enquire about our programmes, enrol as participants, and visit our website.
Boon Capital operates under Thai law and the Personal Data Protection Act B.E. 2562 (PDPA), which governs personal data processing in Thailand. Where participants are based in European Union member states, we also observe relevant principles of the General Data Protection Regulation (GDPR) as a matter of practice.
Questions about this policy may be directed to: [email protected]
What Personal Data We Collect
We collect only the information necessary to administer our programmes and respond to enquiries. This includes:
- Enquiry data: Name, email address, phone number (if provided), and message content submitted through our contact form or by email.
- Enrolment data: Name, email address, phone number, residency status (Thai national or expatriate), and payment confirmation details for invoicing.
- Programme participation data: Written feedback submitted after sessions, and — for the Investing Apprenticeship — learning journal entries shared with the facilitator.
- Website usage data: Technical information collected automatically, including IP address, browser type, and pages visited, where analytics cookies are accepted.
Legal Basis for Processing
- Contract performance: To enrol you in a programme and administer your participation.
- Consent: To send you information about future cohorts, where you have indicated willingness to receive it.
- Legitimate interests: To improve our curriculum and respond to enquiries, where this does not override your rights and interests.
How We Use Personal Data
- To respond to enquiries and provide information about cohort availability
- To process enrolment and send pre-session materials
- To administer payment and issue receipts
- To notify you of future cohort dates, where you have indicated interest
- To improve our programmes using anonymised feedback
We do not share personal data with financial product providers, marketing agencies, or any third party for commercial purposes. Programme participant data is not sold or transferred.
Data Retention
- Enquiry records: Retained for 12 months from the date of the enquiry if no enrolment follows.
- Enrolment and payment records: Retained for 5 years to meet Thai accounting obligations.
- Learning journal entries: Destroyed at the conclusion of the Apprenticeship programme to which they relate. They are not retained.
- Anonymous feedback: Retained indefinitely in aggregated form for curriculum improvement purposes.
Data Protection Measures
We take reasonable technical and organisational measures to protect personal data, including encrypted storage of digital records, restricted access on a need-to-know basis, and physical security for paper documents. In the event of a data breach that affects your rights, we will notify you as promptly as circumstances permit.
Cookies
Our website uses cookies to support basic functionality and, where consent is given, to understand how the site is used. For a full explanation of the cookies we use and how to manage your preferences, please read our Cookie Policy.
Your Rights
Under the Thai PDPA and, where applicable, GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of data we no longer have a lawful basis to retain
- Withdraw consent where processing is based on consent
- Object to processing based on legitimate interests
- Request a portable copy of data you have provided to us
- Lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) in Thailand
To exercise any of these rights, contact: [email protected]. We will respond within 30 days.
Children's Privacy
Our programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently collected such data, please contact us at [email protected] and we will delete it promptly.
Third-Party Links
Our website may include links to external sites. We are not responsible for the privacy practices of those sites and recommend you read their respective policies before providing personal information to them.
Changes to This Policy
If we make material changes to this policy, we will update the date at the top of this page. For significant changes affecting your rights, we will make reasonable efforts to notify active participants by email. Continued use of our website following an update constitutes acceptance of the revised policy.
Contact for Data Matters
Data controller: Boon Capital
Address: 92 Rama IV Road, Pathumwan, Bangkok 10330, Thailand
Email: [email protected]
Telephone: +66 2 458 6093