Privacy and Cookie Policy

1. Who is responsible for your data

The organisation that determines the purposes and means of processing your personal data (the “data controller”) is Khonsu Property Co., Ltd. (บริษัท คอนซู พร็อพเพอร์ตี้ จำกัด), registration number 0835566043723, with its registered address at 189/5 Moo 2, Koh Kaew, Mueang Phuket, Phuket 83000, Thailand. Khonsu Property is part of the Khonsu group of companies. All company employees are required to follow internal data protection rules when handling personal data. If you have any questions about this statement, you can contact us at info@khonsuproperty.com.

2. Personal data we collect

Depending on how you interact with us, we may collect the following categories of information:

• Identification and contact details – your name, telephone number, email address, messaging app usernames (WhatsApp, Telegram, MAX), and your country or city of residence if you have provided them.
• Enquiry details – information you choose to provide through a website form, by telephone or email, via WhatsApp, Telegram, MAX or similar channels: your purpose for buying, budget, timeframes, areas and projects of interest, and the history of our correspondence.
• Data needed for a purchase – information requested by the developer or seller to arrange a reservation and sale and purchase agreement, including passport details and address, information about payments under the payment schedule (such as bank transfer confirmations), and a power of attorney if you are buying property remotely.
• Sensitive data – we do not request data classified as sensitive under applicable law (such as information about health, religious beliefs or biometric data). If documents you provide contain such information, we process it only to the extent necessary for the transaction and only with your consent or where another lawful basis under the PDPA or GDPR applies.
• Technical and website usage data – your IP address, browser and device type, information about pages viewed, and information about the source that brought you to the site, including advertising tags (UTM parameters) and advertising platform click identifiers. This data is collected using cookies and analytics and advertising tools; information about the source is also recorded in our enquiry log. See section 7 for details.
• Data from third parties – developers and sellers may provide us with information about the status of the reservation, contract and payments relating to your purchase. We may also receive your contact details from Khonsu group companies if you contacted them and agreed to be contacted by us, or from a person who recommended our services to you, with your consent.

3. How and why we use your data

We process personal data only where we have a lawful basis. In practice, we use it for the following purposes:

• to answer your questions, select properties suited to your goals, arrange in-person or video viewings and advise you on selected projects – to take steps at your request before entering into a contract and on the basis of performing our contract with you;
• to arrange a reservation and purchase with the developer or seller, and assist with scheduled payments, property acceptance and registration – on the basis of performing our contract with you;
• to send communications relating to your purchase, including payments, construction progress, property acceptance and the handover of keys;
• to operate and secure our business and website, maintain necessary records, and prevent fraud and misuse of the website – on the basis of our legitimate interests;
• to assess the effectiveness of our website and advertising, including identifying the source of an enquiry and reporting advertising results to advertising platforms as described in section 7 – on the basis of our legitimate interests and, for advertising cookies, your consent;
• to comply with obligations under Thai law, including accounting and tax requirements and, where applicable, anti-money laundering requirements – to comply with legal obligations;
• to improve our website and communications – on the basis of our legitimate interests – and, with your consent, to send you occasional property selections, news and informational materials on the basis of that consent.

4. Use of artificial intelligence

If we use artificial intelligence software to process information, such as enquiries and requests, these tools are first assessed against our ethical and legal standards. We do not allow decisions that have legal or similarly significant effects on you to be made solely by automated means – responsibility always remains with a member of our team.

5. When we share your data

We never sell your personal data. We share it only in the circumstances listed below and only to the extent necessary for the relevant purpose:

• Property developers and sellers – if you decide to reserve or buy a property: to arrange the reservation and sale and purchase agreement, process payments and hand over the property. The developer or seller processes this data as an independent data controller under its own privacy policy.
• Khonsu group companies, including Khonsu Legal – if you ask us to pass on your request for legal, tax or other services, such as a project or contract review. That company processes the data as an independent data controller under its own privacy policy.
• Property management companies and other partners – if you ask us to put you in touch with them, for example for property management or rental services.
• Trusted service providers that help us operate, for example by providing website and data hosting, our customer relationship management (CRM) system, messaging and email services, or IT support. They are required to protect the data and use it only in accordance with our instructions.
• Advertising and analytics platforms (Google, Meta, Yandex) – to the extent described in section 7.
• Professional and financial service providers, including banks, lawyers, accountants, auditors and notaries, where their involvement is necessary for the transaction or for us to fulfil our obligations.
• A buyer or successor in the event of a company reorganisation or transfer of its business, provided the safeguards set out in this statement are observed.
• Authorities or courts, where disclosure is required by law, regulation or a legally binding order.

6. Your choices about marketing communications

If we send you property selections, news or informational materials, you remain in control of whether you receive them. You can unsubscribe at any time by using the unsubscribe link in any email we send, replying “Stop” to a message in a messaging app, or emailing a request to info@khonsuproperty.com. Opting out of marketing communications does not stop communications relating to a purchase with which we are assisting you.

7. Cookies and similar technologies

Cookies are small text files stored on your device when you visit a website. They enable the website to work properly, remember your preferences, help us understand how visitors use the site and assess the effectiveness of our advertising. We do not sell your data.

We use the following categories of cookies and similar technologies:

• Strictly necessary – enable the website to operate securely and remember your cookie choices. They cannot be disabled in the settings window.
• Functional – remember your preferences on the website.
• Analytics – help us assess how visitors use the website. For this purpose, we use Google Analytics 4 (Google LLC, USA) and Yandex Metrica (Yandex; data is processed on servers in the Russian Federation). These tools collect aggregated information about website use, including pages viewed and traffic sources. Yandex Metrica may also provide heatmaps and session recordings (Webvisor) showing actions on pages, such as clicks and scrolling; the contents of form fields are not recorded. Yandex Metrica data is also used to assess the effectiveness of our advertising on Yandex. Analytics tools operate on the basis of our legitimate interests and are independent of your choices in the “Cookie settings” window; you can disable them using the methods described below.
• Advertising and targeting – used only with your consent. These include Google Ads tools (Google LLC, USA) and the Meta Pixel (Meta Platforms, Inc., USA). They help us determine which advertising led to an enquiry and show our advertising to people who have already visited the website. These cookies are not used if you have not given consent or have withdrawn it.

Enquiry log. We maintain our own log of clicks on contact buttons (WhatsApp, Telegram, MAX, telephone, email) and form submissions on the website. It records the time, page and source information, including advertising tags and click identifiers, so that an enquiry can be linked to the source from which it came. The log is stored with our cloud infrastructure provider for no more than 24 months.

Information for advertising platforms. If you submit an enquiry, we may send Google, Meta and Yandex information that an enquiry has been received, together with your email address and telephone number in an encrypted (hashed) form. This allows the advertising platform to match the enquiry to the advertising that preceded it without receiving your contact details in plain text.

Each provider acts as an independent data controller for the information it receives and processes it in accordance with its own privacy policy (Google, Meta, Yandex). As the providers are located outside Thailand and the EU, use of these tools involves international data transfers – see section 10.

You can manage cookies yourself. You can choose categories in the “Cookie settings” window, which is linked at the bottom of every page. Most browsers also allow you to view, block and delete cookies through privacy settings, as well as reject new cookies. However, some website features may not work properly if you do so. To opt out of analytics tools, you can install the Google Analytics Opt-out Browser Add-on, which disables Google Analytics on all websites you visit, and follow Yandex’s instructions for opting out of data collection to disable Yandex Metrica. You can limit personalised advertising through the advertising settings in your Google and Meta accounts.

8. Your rights regarding personal data

Subject to the conditions set out in the PDPA and GDPR, you have the right to request access to the data we hold about you, correct inaccurate information, delete data, restrict or object to its processing, have data transferred to another service provider, or withdraw consent previously given. To make a request, email info@khonsuproperty.com. We will respond within the period required by applicable law – generally no later than 30 days.

9. How we keep your data secure

We apply appropriate technical and organisational safeguards, including limiting access to those who genuinely need it, encrypting stored data and providing regular staff training. These measures are designed with recognised information security standards in mind. No safeguard can guarantee absolute security; if a breach occurs that poses a risk to your data, we will notify you and the competent authority within the timeframes required by law.

10. Transfers of data outside Thailand

Some service providers and other parties involved in our operations are located in other countries, so your data may be transferred outside Thailand. In such cases, we apply recognised safeguards, such as standard contractual clauses or an adequacy decision, to ensure an equivalent level of protection for your data in accordance with the PDPA and GDPR.

11. How long we keep your data

We retain information about your purchase and transaction support for as long as necessary to fulfil our obligations to you and our legal obligations – generally ten years after completion of the transaction, and longer if necessary for ongoing compliance work. Information from website, telephone and messaging enquiries that do not result in a purchase is retained for no more than 24 months after the last contact, after which it is deleted or anonymised. The enquiry log described in section 7 is retained for no more than 24 months.

12. Other important information

• If you choose not to provide data requested by the developer or seller to arrange a reservation or contract, we may be unable to arrange the reservation or assist with the purchase.
• Automated decisions. We do not make decisions about you based solely on automated processing of data.
• “Do Not Track”. As there is no uniform industry standard for handling browser “Do Not Track” signals, our website does not currently respond to them.
• Other websites. Our pages may contain links to websites we do not control, such as those of developers or Khonsu group companies. This statement does not apply to their practices, so we recommend that you review their own privacy notices.
• Children. Our services are intended for adults and organisations, and we do not knowingly collect children’s personal data.

13. Changes to this statement

We may revise this statement to reflect changes in our activities or the law. The current version is always available at this address, and the date of the last update appears at the top of the page. If we make material changes, we will notify clients whose purchases we are assisting with by email or messaging app.

14. How to contact us

For any privacy-related questions, requests or complaints, contact us at info@khonsuproperty.com or write to our registered office address above. If you believe we have not resolved your concern, you may lodge a complaint with Thailand’s Personal Data Protection Committee (PDPC) or, if you are in the EU, the relevant local supervisory authority.