Privacy Policy
Version: 4 August 2026. Prepared with regard to the EU General Data Protection Regulation (GDPR), the UK GDPR and Thailand's Personal Data Protection Act (PDPA).
1. Data Controller
Controller: Tumanov Group Co., Ltd., a company incorporated in the Kingdom of Thailand, registered address: 27/343 Moo 6, Srisunthon, Thepkrasattri, Thalang, Phuket 83110, Thailand. Contact e-mail for privacy matters: info@peylaaphuketresidences.com. Website: https://peylaaphuketresidences.com ("Website").
Tumanov Group Co., Ltd. is a partner sales agency for the project and is not the developer.
2. Data We Collect
2.1. Data you submit in the enquiry form on the Website: your name and phone number. The form also records the page you sent the enquiry from and the date and time of submission.
2.2. If you contact us through WhatsApp or Telegram instead of the form, we receive the data your messenger shows us (your profile name, phone number or handle) and the content of your messages. Your use of the messenger itself is governed by that provider's own privacy policy.
2.3. Technical data. Essential cookies and browser local storage are always used: your currency preference, saved favourite units and your cookie-banner choice. In addition, with your consent given through the cookie banner, we use web analytics: cookies and identifiers, IP address, browser and device information, pages viewed and referring source. We do not use advertising pixels and do not build advertising profiles of visitors.
2.4. We do not process special categories of data, biometrics, or data of children.
3. Purposes and Legal Bases
(a) Replying to your enquiry, sending price lists, floor plans, payment schedules and calculations, and arranging viewings — legal basis: your consent, given by ticking the box in the form (GDPR Art. 6(1)(a); PDPA s.19), and steps taken at your request prior to entering into a contract (GDPR Art. 6(1)(b)).
(b) Keeping a record of the consent you gave (the text of the consent, date, time and page) — legal basis: our legal obligation to demonstrate compliance (GDPR Art. 5(2), Art. 7(1)).
(c) Basic protection of the Website against spam and abuse — legal basis: our legitimate interest (GDPR Art. 6(1)(f)).
We do not send marketing newsletters and do not use your data for automated decision-making.
4. Recipients
Your data is accessible to the Controller's sales team and, only where it is necessary to answer your specific enquiry, to the project developer's sales office in Thailand and partner brokers — limited to name, phone and the substance of the enquiry. Our hosting provider processes the data on our behalf as a processor. We do not sell personal data and do not share it for third-party marketing.
5. International Transfers
The Controller is established in Thailand and the property is located in Thailand, so your data is stored and processed in Thailand and may be transferred to recipients there. Thailand is not covered by an EU adequacy decision. For visitors from the EU/EEA and the UK, such transfers take place on the basis of your explicit consent to the transfer, given when you submit the form (GDPR Art. 49(1)(a); UK GDPR Art. 49(1)(a)), and, where applicable, because the transfer is necessary for pre-contractual steps taken at your request (Art. 49(1)(b)). We inform you that Thai law may provide a lower level of protection than EU law and that supervisory-authority remedies may be harder to enforce there.
6. Retention
We keep enquiry data no longer than necessary for the purposes above and in any case no longer than 24 months after our last interaction with you, unless a longer period is required by law or to establish or defend legal claims. Records of consent are kept for the same period. After that, data is deleted or anonymised.
7. Cookies, Local Storage and Analytics
7.1. Essential cookies and local storage work without consent and cannot be switched off: currency preference, saved favourite units, your answer in the cookie banner. They are not used for tracking or advertising.
7.2. Analytics cookies load only after you accept them in the cookie banner. We use Google Analytics 4 (provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to understand which pages are useful and where visitors lose their way. Data is processed in aggregated form; IP addresses are truncated; the advertising features and data sharing with Google advertising products are switched off; the retention period is set to the minimum available.
7.3. Google may transfer data to servers outside the EU, including the United States. Such transfers rely on Google's standard contractual clauses and its participation in the EU–US Data Privacy Framework.
7.4. You can withdraw your consent at any time through the cookie banner or by clearing cookies in your browser. Declining analytics does not limit access to the Website.
7.5. Legal basis for analytics: your consent (GDPR Art. 6(1)(a); ePrivacy). Until consent is given, no analytics scripts are loaded.
8. Your Rights
Subject to applicable law (GDPR / UK GDPR Art. 15–21; PDPA s.30–36), you may request: access to your data, rectification, erasure, restriction of processing, data portability; you may object to processing; and you may withdraw your consent at any time, which does not affect the lawfulness of processing carried out before the withdrawal. To exercise your rights, write to info@peylaaphuketresidences.com — we reply within 30 days. EU/EEA and UK residents may lodge a complaint with their national supervisory authority (in the UK — the Information Commissioner's Office); residents of Thailand — with the PDPC.
9. Security
We apply organisational and technical measures: HTTPS encryption in transit, restricted access to enquiry records, confidentiality obligations for staff, and internal access rules.
10. Changes
The current version is always published on this page; the version date is updated upon material changes.