Privacy Policy

Effective Date: 1 June 2025

Last Updated: 16 September 2025

1. Introduction

This Privacy Policy explains how Andrè Vermeulen ("we," "us," or "our") collects, uses, discloses, and protects your personal data when you visit our personal website andrevermeulen.com (the "Website"). This policy complies with Thailand's Personal Data Protection Act B.E. 2562 (2019) ("PDPA") and applies to all visitors and users of our Website.

Please note: This is a personal website operated by an individual for sharing professional experiences, insights, and personal perspectives. While we maintain high standards for data protection, this site is primarily personal in nature.

We are committed to protecting your privacy and ensuring transparency in how we handle your personal data.

2. Data Controller Information

Data Controller: Andrè Vermeulen

Website: andrevermeulen.com

Contact: andre@andrevermeulen.com

3. Personal Data We Collect

3.1 Information You Provide Directly

When you interact with our Website, we may collect:

Contact information (name, email address, phone number) when you submit inquiry forms
Professional information shared through contact forms or communications
Any other information you voluntarily provide when contacting us

3.2 Information Collected Automatically

We automatically collect certain information through:

Google Analytics:

IP address (anonymized)
Browser type and version
Device information (device type, operating system)
Pages visited and time spent on pages
Referral sources (how you found our website)
Geographic location (country/city level)
Session duration and bounce rate

Technical Information:

Cookies and similar tracking technologies
Log files and usage data

4. Legal Basis for Processing

Under Thailand's PDPA, we process your personal data based on the following legal grounds:

Consent: When you voluntarily provide information through contact forms or consent to analytics tracking
Legitimate Interest: For website analytics to improve user experience and website functionality
Performance of Contract: When processing is necessary for services you've requested

5. How We Use Your Personal Data

We use your personal data for the following purposes:

5.1 Website Analytics

Monitor website traffic and user behavior
Improve website functionality and user experience
Generate statistical reports (anonymized)
Optimize content and navigation

5.2 Communication

Respond to your inquiries and requests
Provide information about our services (supply chain consulting, coaching, photography)
Send follow-up communications related to your interests

5.3 Legal Compliance

Comply with applicable laws and regulations
Maintain records as required by law

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your personal data only in the following circumstances:

Third-Party Service Providers:

Google Analytics: For website traffic analysis (data is processed according to Google's privacy policy and data processing terms)

Legal Requirements:

When required by law, court order, or government authorities
To protect our legal rights, safety, or security

7. International Data Transfers

Google Analytics Data Transfer: Your data may be transferred to and processed by Google in countries outside Thailand, including the United States. Google has implemented appropriate safeguards, including:

Google's commitment to data protection frameworks
Standard Contractual Clauses for international transfers
Technical and organizational security measures

We ensure all international transfers comply with PDPA requirements for cross-border data protection.

8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

Contact form data: Retained for up to 2 years or until you request deletion
Google Analytics data: Automatically expires after 26 months
Communication records: Retained for up to 3 years for business record-keeping

9. Your Rights Under Thailand's PDPA

As a data subject under Thailand's PDPA, you have the following rights:

9.1 Right of Access

Request information about personal data we hold about you, including:

What personal data we process
Purposes of processing
Categories of recipients
Retention periods

9.2 Right to Rectification

Request correction of inaccurate or incomplete personal data

9.3 Right to Erasure

Request deletion of your personal data when:

No longer necessary for the original purpose
You withdraw consent and no other legal ground applies
Data has been unlawfully processed

9.4 Right to Restrict Processing

Request limitation of processing in certain circumstances

9.5 Right to Data Portability

Request transfer of your data in a structured, commonly used format

9.6 Right to Object

Object to processing based on legitimate interests or for direct marketing

9.7 Right to Withdraw Consent

Withdraw previously given consent at any time

How to Exercise Your Rights: Contact us at andre@andrevermeulen.com. We will respond to your request within 30 days as required by PDPA.

10. Consent

By using our Website, you consent to:

Collection of personal data through Google Analytics
Use of cookies for website functionality and analytics
Processing of any information you voluntarily provide

Withdrawing Consent: You may withdraw your consent at any time by:

Contacting us directly
Adjusting your browser settings to block cookies
Using browser "Do Not Track" settings

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Technical Measures:

SSL encryption for data transmission
Secure hosting infrastructure
Regular security updates and monitoring

Organizational Measures:

Access controls limiting data access to authorized personnel
Regular privacy and security training
Data breach response procedures

12. Cookies Policy

Our Website uses cookies and similar technologies:

12.1 Types of Cookies Used

Google Analytics Cookies:

_ga: Distinguishes unique users (expires: 2 years)
_ga_[ID]: Maintains session state (expires: 2 years)
_gid: Distinguishes unique users (expires: 24 hours)

Functional Cookies:

Session cookies for website functionality
Preference cookies (if applicable)

12.2 Managing Cookies

You can control cookies through your browser settings:

Block all cookies
Delete existing cookies
Set preferences for cookie acceptance

Note: Disabling cookies may affect website functionality.

13. Data Breach Notification

In the event of a data breach that may result in high risk to your rights and freedoms, we will:

Notify the Personal Data Protection Committee within 72 hours
Notify affected individuals without undue delay
Provide information about the breach and steps taken

14. Children's Privacy

Our Website is not directed at children under 20 years of age. We do not knowingly collect personal data from minors without appropriate parental consent as required by PDPA.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will:

Post the updated policy on our Website
Update the "Last Updated" date
Notify you of material changes if required by law

16. Contact Us

For any questions about this Privacy Policy or to exercise your rights under PDPA, please contact us:

Email: andre@andrevermeulen.com

Website: andrevermeulen.com

17. Complaints

If you believe we have not handled your personal data in accordance with this policy or PDPA requirements, you may file a complaint with:

Personal Data Protection Committee (PDPC)

Website: https://www.pdpc.or.th