1. Information We Collect

We collect different types of information depending on how you interact with our services. Here's what we gather and why:

Personal Information You Provide

When you sign up for our learning programs or contact us, you voluntarily share information such as:

• Contact details: Name, email address, phone number, and mailing address
• Account credentials: Username and password for accessing our platform
• Payment information: Billing details processed through secure third-party payment processors
• Learning preferences: Trading experience level, educational goals, and areas of interest
• Communication records: Messages you send us through contact forms or support channels

Automatically Collected Information

Our platform collects certain technical data automatically to improve your experience:

• Device information: Browser type, operating system, device identifiers
• Usage data: Pages visited, time spent on site, navigation patterns
• IP address: For security purposes and geographic analytics
• Cookies and tracking: Session cookies for functionality and analytics cookies for site improvement

2. How We Use Your Information

We process your data for legitimate business purposes related to providing quality financial education. Specifically, we use your information to:

• Deliver educational services: Provide access to courses, materials, and learning resources you've enrolled in
• Process transactions: Handle payments, send receipts, and manage your account billing
• Communicate with you: Send course updates, respond to inquiries, and share relevant educational opportunities
• Improve our platform: Analyze usage patterns to enhance content quality and user experience
• Ensure security: Protect against fraud, unauthorized access, and maintain platform integrity
• Comply with legal obligations: Meet requirements under Thai law and international regulations
• Marketing communications: Share updates about new courses or features (you can opt out anytime)

Our legal basis for processing depends on the context. Generally, we rely on contractual necessity (to provide services you've requested), legitimate interests (to improve our platform), and consent (for optional communications).

3. Data Sharing and Disclosure

We share your information only when necessary to operate our business or as required by law. Here's who might access your data:

All third-party service providers are contractually bound to protect your data and use it only for the specific purposes we authorize. We conduct regular reviews to ensure they maintain appropriate security standards.

4. Your Rights Under Thai Law

Thailand's Personal Data Protection Act (PDPA), effective since 2022, grants you significant control over your personal information. You have the right to:

• Access your data: Request a copy of the personal information we hold about you
• Rectification: Correct inaccurate or incomplete information in your account
• Erasure: Request deletion of your data when it's no longer necessary for the purposes collected
• Restrict processing: Limit how we use your information in certain circumstances
• Data portability: Receive your data in a structured, commonly used format
• Object to processing: Opt out of certain uses of your information, particularly for marketing
• Withdraw consent: Revoke permission for processing based on consent (doesn't affect prior lawful processing)
• Lodge a complaint: File concerns with the Personal Data Protection Committee if you believe we've mishandled your data

To exercise these rights, contact us at support@pondercortex.com. We'll respond within 30 days and may request verification of your identity to protect against unauthorized access.

5. Data Security Measures

Protecting your information is a priority. We implement multiple layers of security to safeguard against unauthorized access, alteration, or disclosure:

• Encryption: All data transmitted between your device and our servers uses TLS/SSL encryption
• Access controls: Strict employee access policies with role-based permissions and regular audits
• Secure storage: Data stored on encrypted servers with regular backups in secure locations
• Authentication: Strong password requirements and optional two-factor authentication for accounts
• Regular testing: Periodic security assessments and vulnerability scans to identify risks
• Incident response: Documented procedures for detecting, reporting, and responding to data breaches

Despite our best efforts, no online platform is completely invulnerable. If a security breach occurs that affects your data, we'll notify you and relevant authorities as required by Thai law, typically within 72 hours of discovery.

6. Data Retention and Deletion

We don't keep your information longer than necessary. Our retention periods vary based on data type and legal requirements:

When retention periods expire, we securely delete or anonymize your data. You can request earlier deletion in some cases, though we may need to retain certain information for legal obligations or legitimate business needs.

7. International Data Transfers

While we primarily operate in Thailand, some of our service providers are based internationally. When we transfer your data outside Thailand, we take steps to ensure it receives adequate protection:

• We work only with providers in countries recognized by Thai authorities as having adequate data protection standards
• We implement Standard Contractual Clauses approved by relevant data protection authorities
• We require all international partners to maintain security measures equivalent to those mandated by Thai law
• We regularly review cross-border data flows to minimize unnecessary transfers

If you have concerns about international transfers of your data, contact us to discuss the specific safeguards in place.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance functionality and understand how you use our platform. Here's what you should know:

Types of Cookies We Use

• Essential cookies: Required for basic site functionality like logging in and security (these can't be disabled)
• Performance cookies: Help us understand how visitors interact with our site through anonymous statistics
• Functional cookies: Remember your preferences and settings to personalize your experience
• Marketing cookies: Track your activity to show relevant educational content (requires consent)

You can control cookie preferences through your browser settings. Keep in mind that blocking certain cookies may limit site functionality. We respect Do Not Track signals when technically feasible.

9. Children's Privacy

Our services are designed for adults interested in financial education. We don't knowingly collect information from individuals under 18 years old without parental consent, as required by Thai law.

If we discover we've inadvertently collected data from someone under 18 without proper authorization, we'll delete it promptly. Parents or guardians who believe their child has provided us with personal information should contact us immediately.

10. Changes to This Policy

We update this privacy policy periodically to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we'll notify you by:

• Posting the updated policy on this page with a new effective date
• Sending an email to your registered address for material changes
• Displaying a prominent notice on our platform for 30 days

We encourage you to review this policy periodically. Your continued use of our services after changes take effect constitutes acceptance of the updated terms.