Privacy Policy

Last Updated: January 15, 2025

At Cognitfluxonhub, we take your privacy seriously. This policy explains how we collect, use, and protect your personal information when you interact with our financial modeling education platform. We've designed our practices to comply with Thailand's Personal Data Protection Act (PDPA) and international standards.

We're not here to hide behind legal jargon. This document tells you exactly what happens with your data and why we need it.

Information We Collect

When you use our platform, we collect different types of information depending on how you engage with us. Some you give us directly. Other bits we pick up automatically as you navigate the site.

Information You Provide Directly

  • Contact details: name, email address, phone number when you sign up or reach out
  • Payment information when enrolling in our programs (though we don't store full card details ourselves)
  • Professional background and educational history for program placement
  • Learning preferences and goals you share during onboarding
  • Questions, feedback, or content you submit through our platform

Information We Collect Automatically

Like most websites, we automatically gather some technical data:

  • Your IP address and general location (city level, not your exact address)
  • Browser type, device information, and operating system
  • Pages you visit and how long you spend on them
  • Links you click and actions you take on our site
  • Date and time stamps of your visits

How We Use Your Information

We're running an education business, not a data broker. Everything we collect serves a specific purpose related to providing and improving our financial modeling programs.

  • Program Delivery: We need your contact info to communicate about courses, send materials, and provide support when you're stuck on a particularly tricky Excel formula at 11 PM.
  • Payment Processing: Financial transactions require certain data. We work with secure payment processors who handle the sensitive bits.
  • Personalization: Your learning history helps us suggest relevant content and adjust difficulty levels. If you're breezing through valuation models, we might recommend our advanced merger modeling track.
  • Platform Improvement: Usage patterns tell us which lessons work well and which need reworking. If everyone's dropping off at the same video, that's a signal.
  • Communication: We'll send course updates, schedule changes, and occasionally information about new programs that match your interests.
  • Legal Compliance: Sometimes we're required to maintain records for tax purposes or other regulatory requirements in Thailand.

Legal Basis for Processing

Under Thailand's PDPA, we need a lawful reason to process your data. Here's what applies to us:

Processing Activity Legal Basis
Course enrollment and delivery Contract performance
Payment processing Contract performance
Marketing communications Your consent (you can opt out anytime)
Platform analytics Legitimate business interests
Legal record keeping Legal obligation

Who We Share Your Data With

We don't sell your information to anyone. That said, running an online education platform means working with some trusted partners:

  • Payment Processors: Secure third-party services handle credit card transactions. They're bound by strict financial regulations.
  • Email Services: We use established platforms to send course communications and updates. Your email stays on their secure servers.
  • Cloud Hosting: Course materials and user data live on reputable cloud infrastructure with strong security practices.
  • Analytics Tools: We use standard web analytics to understand how people use our site. These tools collect anonymized data.
  • Customer Support: If you contact support, our help desk software processes your inquiry and history.

Important: All our third-party partners sign agreements requiring them to protect your data and use it only for specified purposes. We vet these companies before working with them.

International Data Transfers

Some of our service providers operate servers outside Thailand. When your data crosses borders, we ensure it's protected through:

  • Standard contractual clauses approved by data protection authorities
  • Selecting providers in countries with adequate data protection laws
  • Additional security measures like encryption during transfer and storage

You have the right to request details about any international transfers involving your personal data.

Your Rights Under Thailand PDPA

Thailand's data protection law gives you significant control over your information. Here's what you can do:

Access and Portability

You can request a copy of all personal data we hold about you. We'll provide it in a commonly used format within 30 days. If you want to transfer your data to another service, we'll help make that happen.

Correction and Completion

Spotted an error in your profile? Let us know and we'll fix it. If your information is incomplete, you can request we add the missing pieces.

Deletion (Right to be Forgotten)

You can ask us to delete your personal data in these situations:

  • We no longer need it for the original purpose
  • You withdraw consent and there's no other legal basis for processing
  • You object to processing and we have no overriding legitimate grounds
  • We've processed your data unlawfully

Note: We might need to keep certain records for legal or accounting purposes even after you request deletion.

Restriction of Processing

In some cases, you can ask us to limit how we use your data rather than deleting it entirely. This applies when you're disputing data accuracy or contesting whether we have legitimate grounds to process it.

Objection

You can object to processing based on legitimate interests or for direct marketing purposes. We'll stop unless we can demonstrate compelling reasons that override your interests.

Withdrawal of Consent

For processing based on consent, you can withdraw it anytime. This won't affect the lawfulness of processing before withdrawal.

How to Exercise Your Rights: Send your request to [email protected]. We'll verify your identity and respond within 30 days. There's no fee unless your request is clearly unfounded or excessive.

Data Security Measures

We take protection seriously. While no system is 100% secure (anyone claiming otherwise is lying), we've implemented multiple layers of defense:

  • Encryption: Data transmitted to and from our site uses TLS encryption. Sensitive data at rest is also encrypted.
  • Access Controls: Only authorized staff can access personal data, and only when necessary for their role. We maintain detailed logs of who accesses what.
  • Regular Security Audits: We conduct quarterly reviews of our security practices and systems.
  • Secure Development: Our development team follows security best practices and tests for vulnerabilities before deploying updates.
  • Incident Response Plan: We have procedures ready in case of a data breach, including rapid notification protocols.
  • Staff Training: Everyone at Cognitfluxonhub receives regular training on data protection and security.

If we detect a breach that poses a risk to your rights, we'll notify you and the relevant authorities within 72 hours as required by PDPA.

Data Retention

We don't keep your data forever. Here's how long we typically retain different types of information:

Data Type Retention Period
Active student records Duration of enrollment plus 2 years
Financial records 7 years (Thai tax law requirement)
Marketing consent records Until consent is withdrawn, then deleted
Support inquiries 3 years after resolution
Website analytics 26 months (anonymized data)

When retention periods expire, we securely delete or anonymize the data. Anonymized data doesn't identify you personally and can be kept for statistical purposes.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies. These small files help the site function properly and give us insight into usage patterns.

Types of Cookies We Use

  • Essential Cookies: Required for basic site functionality like maintaining your login session. You can't opt out of these without breaking the site.
  • Performance Cookies: Help us understand how visitors use the site by collecting anonymized data about page views and navigation paths.
  • Functionality Cookies: Remember your preferences like language settings or playback speed for videos.
  • Analytics Cookies: Provide detailed information about site usage, helping us improve the user experience.

You can control cookies through your browser settings. Most browsers let you block or delete cookies, though this might affect site functionality. Our site will ask for your cookie preferences on your first visit.

Children's Privacy

Our programs are designed for adults and professionals. We don't knowingly collect information from anyone under 18. If you're a parent who believes your child has provided us with personal data, contact us immediately and we'll delete it.

Changes to This Policy

We update this policy occasionally to reflect changes in our practices or legal requirements. When we make significant changes, we'll notify you through email or a prominent notice on our site. The "Last Updated" date at the top tells you when the most recent changes were made.

We recommend reviewing this policy periodically, especially before providing new information or using new features.

Third-Party Links

Our site might contain links to external websites or services. This privacy policy only covers Cognitfluxonhub. We're not responsible for how other sites handle your data, so check their privacy policies before sharing information.

Complaints and Disputes

If you have concerns about how we handle your personal data, please contact us first. We'll do our best to resolve the issue.

You also have the right to file a complaint with Thailand's Personal Data Protection Committee (PDPC) if you believe we've violated the PDPA. However, we'd appreciate the opportunity to address your concerns directly before you escalate to regulatory authorities.

Contact Information

For questions about this privacy policy or to exercise your data rights, reach out to us:

Cognitfluxonhub
313 Soi Si Lom 2/1, Silom, Bang Rak
Bangkok 10500, Thailand

Email: [email protected]
Phone: +66 2 447 8597

We typically respond to privacy inquiries within 3 business days.