Privacy Policy

1. Introduction

Luxauct Counsel ("we", "us", "our") is committed to handling personal data with care and transparency. This Privacy Policy describes the personal data we collect, the purposes for which we use it, the legal basis for that use, and the rights available to individuals whose data we hold.

This policy applies to personal data collected through our website at luxxauctions.com, through enquiry forms, and through communications with our office at 268 Sathorn Road, Yan Nawa, Sathon, Bangkok 10120, Thailand.

We are the data controller of personal data collected through these channels. Questions about this policy may be directed to [email protected].

2. Personal Data We Collect

2.1 Data You Provide Directly

When you complete an enquiry form on our website or contact us by email or telephone, we may collect:

• Your full name
• Your email address
• Your telephone number (if provided)
• The content of your message or description of your matter
• Your company name and role (if provided)

2.2 Data Collected Automatically

When you visit our website, our hosting infrastructure may record standard technical data including your IP address, browser type, pages visited, and the date and time of your visit. This data is used for security monitoring and aggregate site performance analysis and is not linked to your personal identity.

2.3 Cookies

Our website uses cookies to record your cookie consent preference and, where you have consented, to support analytics. See our Cookie Policy for full details.

3. Legal Basis for Processing

We process personal data on the following legal bases under Thailand's Personal Data Protection Act B.E. 2562 (2019) (PDPA):

• Consent — where you have given us explicit consent, for example by submitting an enquiry form or accepting analytics cookies.
• Legitimate interests — where processing is necessary for our legitimate interests in responding to commercial enquiries, maintaining our practice, and improving our services, provided those interests are not overridden by your rights.
• Legal obligation — where processing is required to comply with applicable law or professional regulations.
• Performance of a contract — where processing is necessary to carry out an engagement you have entered into with us.

4. How We Use Personal Data

Personal data collected through our website and communications is used for the following purposes:

• Responding to enquiries and assessing whether an engagement is appropriate
• Conducting conflict-of-interest checks before accepting a new matter
• Providing legal services under an engagement agreement
• Sending written reports, correspondence, and invoices relating to an engagement
• Complying with professional obligations under Thai law and the regulations of the Lawyers Council of Thailand
• Maintaining records as required by law or professional practice
• Improving the performance and content of our website (with your consent)

We do not use personal data for automated decision-making or profiling. We do not send marketing communications without your explicit consent.

5. Data Retention

We retain personal data for the following periods:

• Enquiry data (no engagement): Up to 12 months from the date of the enquiry, after which it is deleted or anonymised.
• Engagement data: For the duration of the engagement and for a period of 7 years following its conclusion, in accordance with professional obligations and applicable limitation periods under Thai law.
• Website analytics data: Up to 26 months, in accordance with standard analytics retention practices.

Where retention is no longer necessary and no legal obligation requires it, personal data is securely deleted.

6. Sharing of Personal Data

We do not sell, rent, or trade personal data. We may share personal data in the following limited circumstances:

• Overseas counsel: In Substantial Litigation Programme engagements, where coordination with overseas counsel is part of the scope, relevant case information may be shared with those counsel to the extent necessary and with your knowledge.
• Service providers: We use trusted third-party services for website hosting and email delivery. These providers process data on our behalf under appropriate data processing agreements and do not use data for their own purposes.
• Legal requirements: We may disclose data where required by Thai law, court order, or applicable professional regulatory obligation.

7. Data Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or alteration. These measures include:

• Encryption of data in transit using TLS/HTTPS protocols
• Access controls limiting data access to personnel who require it for their work
• Secure document storage with restricted physical and digital access
• Regular review of data handling practices

In the event of a personal data breach that is likely to affect your rights and freedoms, we will notify you and, where applicable, the relevant supervisory authority, in accordance with the PDPA.

8. Cookies

We use essential cookies to record your consent preference and, where you have consented, optional cookies for analytics purposes. You can manage your cookie preferences at any time through our Cookie Policy page. Withdrawing consent for non-essential cookies does not affect the functionality of the website.

9. Your Rights Under the PDPA

Under Thailand's Personal Data Protection Act B.E. 2562 (2019), you have the following rights in relation to personal data we hold about you:

• Right of access: You may request confirmation of whether we hold personal data about you and, if so, a copy of that data.
• Right to rectification: You may request that inaccurate or incomplete personal data be corrected.
• Right to erasure: You may request deletion of personal data where retention is no longer necessary and no legal basis for retention applies.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used format.
• Right to object: You may object to processing based on legitimate interests, including for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to restrict processing: In certain circumstances, you may request that processing be restricted while a query about your data is resolved.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may ask you to verify your identity before processing a request.

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the Personal Data Protection Committee of Thailand or another competent supervisory authority.

10. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices or content of those sites. We recommend reviewing the privacy policy of any external site you visit through a link on our website.

11. Children's Privacy

Our services are intended for companies and individuals aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that personal data has been submitted by a minor, we will delete it promptly.

12. International Data Transfers

Where your matter involves overseas counsel or service providers located outside Thailand, personal data may be transferred internationally. We ensure such transfers are carried out with appropriate safeguards in accordance with the PDPA, including entering into data processing agreements with recipients that provide an equivalent level of protection.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law or our data handling practices. We will post the updated version on this page with a revised "Last Updated" date. Where changes are material, we will notify you by email if we hold your contact details. Continued use of our website after an update constitutes acceptance of the revised policy.

14. Contact

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