PRIVACY AND COOKIE POLICY


Effective Date: 20.02.2025

1. Introduction
Your privacy is of paramount importance to Centuno Co., Ltd. («Company,» «we,» or «us»). This Privacy and Cookie Policy outlines how we collect, use, disclose, and safeguard your Personal Data when you access our website at https://centuno360.com/ (the «Website») or engage with our services, including web development, mobile application development, QA/testing, marketing and consulting («Services»). By using the Website or Services, you agree to the terms of this Policy.

2. Types of Personal Data Collected
We collect the following categories of Personal Data, either directly from you or through automated means:

  • Identifiers: Name, email address, phone number, username, User ID, billing address, company name, social media accounts.
  • Demographic/Geographic Data: Country, state, city, ZIP/postal code, geographic position, latitude/longitude (of city).
  • Technical/Usage Data: IP address, device information, browser type, cookies, session statistics, language/region preferences.
  • User-Generated Data: Communications via email or forms, project requirements, passwords, profile pictures, field of activity.
  • Other: Data communicated during service use, preferences, and non-mandatory information (e.g., prefixes).

Mandatory vs. Optional Data:
Unless specified, all requested Data is mandatory. Failure to provide mandatory Data may prevent us from delivering Services. Non-mandatory Data may be omitted without penalty.

3. Automated Data Collection: Cookies and Server Logs
Cookies:

  • Definition: Small text files stored on your device to enhance Website functionality, analyze usage, and personalize content.
  • Types:
    • Strictly Necessary: Essential for Website operation (e.g., login sessions).
    • Performance/Analytics: Track usage patterns (e.g., Google Analytics).
    • Functional: Remember preferences (e.g., language).
    • Targeting/Advertising: Deliver personalized ads (e.g., Facebook Pixel).

Server Logs:
We collect traffic data (e.g., IP addresses, pages viewed, visit times) to monitor security, diagnose issues, and improve performance.

Third-Party Cookies:
Third-party services (e.g., payment processors, social media) may place cookies. We do not control these cookies; review their policies directly.

4. Use of Personal Data
We process your Data to:

  • Provide, improve, and personalize Services.
  • Communicate with you (e.g., respond to inquiries, send updates).
  • Process payments and fulfill contractual obligations.
  • Analyze trends and enhance Website security.
  • Comply with legal obligations (e.g., tax laws, court orders).
  • Deliver marketing communications (with your consent).

5. Email Policies

  • Confidentiality: We do not sell, rent, or lease email lists. Your email address is used solely for Company communications.
  • Content: Emails from us will clearly identify the sender and include unsubscribe instructions.
  • Opt-Out: Click the unsubscribe link in any email or contact us at [Insert Contact Email].

6. User Rights
Under applicable laws (e.g., Thailand’s PDPA, EU GDPR), you may:

  • Withdraw Consent: Opt out of non-essential processing.
  • Access/Portability: Request a copy of your Data in a machine-readable format.
  • Rectify/Delete: Correct inaccuracies or request erasure.
  • Restrict Processing: Limit how we use your Data.
  • Object: Challenge processing based on legitimate interests.
  • Lodge Complaints: Contact your local data protection authority.

To exercise these rights, email [email protected]. We will respond within 30 days.

7. Data Sharing and Security
Third-Party Disclosures:
We share Data with:

  • Service Providers: Payment processors, hosting companies, analytics tools.
  • Legal Authorities: To comply with lawful requests or protect our rights.
  • Affiliates: For service delivery under confidentiality agreements.

Security Measures:

  • Encryption: SSL/TLS for data in transit; encryption at rest.
  • Access Controls: Restricted access to authorized personnel.
  • Monitoring: Software to detect unauthorized access or breaches.

Note: Email is not a secure medium. Avoid transmitting sensitive Data via email.

8. External Links and Intellectual Property
External Sites:
The Website may link to third-party websites. We do not endorse or control their content, privacy practices, or accuracy.

Intellectual Property:
All trademarks, copyrights, and content on the Website are owned by the Company or licensors. You may not:

  • Republish, sell, or redistribute material without written consent.
  • Use our trademarks or content for commercial purposes.
  • Reverse-engineer or exploit Website content.

9. Acceptable Use and Restricted Access
You agree to use the Website lawfully and refrain from:

  • Harassing other users or transmitting offensive content.
  • Disrupting Website functionality or security.
  • Sending unsolicited commercial communications.

We reserve the right to restrict access to parts of the Website and may provide login credentials (kept confidential).

10. Disclaimer and Limitation of Liability
No Warranties:
The Website and Services are provided «as is.» We disclaim all warranties, including accuracy, merchantability, or fitness for purpose.

Liability Cap:
To the fullest extent permitted by law, the Company shall not be liable for:

  • Indirect, incidental, or consequential damages (e.g., lost profits, data loss).
  • Third-party actions or content.
  • Unauthorized access to your account.

11. Policy Changes
We may update this Policy at any time. Material changes will be posted on the Website. Continued use after updates constitutes acceptance.

12. Contact Information
For questions or requests, contact:
 [email protected],  
Registered Address in Thailand : No.34 CP Tower 3, A Building, 4th Floor, Phaya Thai Road, Thung Phaya Thai Sub-district, Ratchathewi District, Bangkok Metropolis.

By using the Website or Services, you acknowledge that you have read, understood, and agree to this Privacy and Cookie Policy.

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