Privacy Policy

Sanet Group under Sanet Holding Co., Ltd.

Effective Date: 12.05.2026

Website: www.sanet-group.com

1. Introduction

Sanet Group, operating under Sanet Holding Co., Ltd., respects your privacy and is committed to protecting personal data.

This Privacy Policy explains how we collect, use, disclose, transfer, store, and protect personal data when you visit our website, contact us, request information, use our services, apply for a position, subscribe to our communications, attend our events, or otherwise interact with Sanet Group.

This Privacy Policy is intended to comply with applicable data protection laws, including the Thailand Personal Data Protection Act B.E. 2562, the European Union General Data Protection Regulation, and, where applicable to individuals in Germany, the German Federal Data Protection Act and the Telecommunications Digital Services Data Protection Act.

2. Who We Are

The data controller responsible for this website and for the processing described in this Privacy Policy is:

Sanet Holding Co., Ltd.

Operating through Sanet Group

Where a specific Sanet-affiliated company provides a service, that company may also act as a data controller or data processor, depending on the nature of the service.

3. Applicable Privacy Laws

As a Thailand-based company, Sanet Group processes personal data in accordance with the Thailand Personal Data Protection Act B.E. 2562. Where Sanet Group offers services to, communicates with, contracts with, recruits from, or monitors website behaviour of individuals located in the European Union or European Economic Area, the European Union General Data Protection Regulation may also apply.

Where individuals are located in Germany, Sanet Group also considers applicable German privacy requirements, including the German Federal Data Protection Act and the Telecommunications Digital Services Data Protection Act, especially for cookies, tracking technologies, analytics, and online marketing.

4. Privacy Contact

Questions, requests, or complaints about personal data may be sent to:

Sanet Group Privacy Contact

  • Sanet Holding Co., Ltd.

  • Address: 2/1 Soi Romklao 25/2, Romklao Road, Khlongsamprawet, Ladkrabang, Bangkok 10520

  • Email: management@sanet-group.com

  • Telephone: +66 2 737 6420

If Sanet Group is required to appoint a Data Protection Officer or an EU representative, the relevant contact details will be made available through this Privacy Policy or another appropriate notice.

5. EU Representative

Where required under Article 27 of the GDPR, Sanet Group will appoint a representative in the European Union to act as a contact point for individuals and supervisory authorities.

  • EU Representative: Axel Michael Denk

  • Address: An Der Aspe 7, Grossenlueder, 36317, Germany

  • Email: support@denkit.com

6. Personal Data We Collect

We may collect the following types of personal data:

  • Identity data, including name, surname, title, nationality, date of birth, passport details, identification details, visa details, work permit details, signature, and documents used to verify identity.

  • Contact data, including email address, telephone number, postal address, business address, residential address, and messaging application details.

  • Business data, including company name, position, department, employer, business registration details, shareholder details, director details, authorised signatory details, professional background, business correspondence, proposals, contracts, and service records.

  • Client service data, including information required to provide consulting, market entry, investment advisory, sales support, legal, accounting, recruitment, digital marketing, operational, corporate, immigration, or related services.

  • Recruitment data, including curriculum vitae, employment history, education, qualifications, references, interview records, salary expectations, work authorisation status, and application materials.

  • Financial and transaction data, including billing information, invoice details, payment status, bank transfer information, tax information, and accounting records.

  • Website and technical data, including IP address, browser type, device type, operating system, pages visited, time and date of visit, time spent on pages, referral source, cookie identifiers, analytics data, and diagnostic data.

  • Marketing data, including newsletter preferences, event attendance, inquiry history, communication preferences, and consent records.

7. Sensitive Personal Data

We may collect sensitive personal data only where necessary and lawful. This may include health information, biometric data, criminal record information, religious information, racial or ethnic origin, disability information, or other sensitive personal data protected by applicable law.

We will process sensitive personal data only where we have a lawful basis, such as explicit consent, legal obligation, employment-related necessity, protection of vital interests, establishment or defence of legal claims, or another basis permitted by applicable law.

8. How We Collect Personal Data

We may collect personal data directly from you when you contact us, submit a form, request services, sign a contract, send documents, attend a meeting, subscribe to communications, apply for a job, or communicate with us by email, phone, social media, messaging applications, or other channels.

We may also collect personal data from clients, employers, candidates, suppliers, business partners, public registers, government authorities, professional networks, recruitment platforms, event organisers, analytics providers, marketing platforms, payment providers, and other lawful sources.

9. Purposes of Processing

We process personal data for the following purposes:

  • To respond to inquiries and provide information about Sanet Group services.

  • To provide consulting, investment advisory, market entry, sales support, recruitment, legal, accounting, digital marketing, operational, corporate, immigration, and related services.

  • To prepare proposals, contracts, invoices, reports, applications, filings, correspondence, and service documents.

  • To verify identity, conduct due diligence, assess eligibility, and comply with compliance checks.

  • To communicate with clients, potential clients, partners, suppliers, applicants, employees, and representatives.

  • To manage client relationships, service delivery, project administration, internal records, and business operations.

  • To process payments, issue invoices, manage accounting, and comply with tax obligations.

  • To manage recruitment, applications, interviews, assessments, employment offers, onboarding, and HR administration.

  • To comply with legal, regulatory, accounting, tax, immigration, labour, corporate, professional, and court-related obligations.

  • To protect our legal rights, prevent fraud, investigate misconduct, resolve disputes, enforce agreements, and defend claims.

  • To operate, maintain, secure, analyse, and improve our website, IT systems, databases, and online services.

  • To send newsletters, publications, event invitations, service updates, and marketing communications where permitted by law or where consent has been obtained.

  • To support business restructuring, mergers, acquisitions, investments, joint ventures, financing, asset transfers, or similar business transactions.

10. Legal Bases Under Thai PDPA

Under the Thailand PDPA, Sanet Group may process personal data based on one or more lawful bases, including consent, contractual necessity, legal obligation, legitimate interest, vital interest, public interest, research or statistics where permitted, and establishment or defence of legal claims.

Where Thai law requires consent, including explicit consent for certain sensitive personal data, we will request consent before processing unless another lawful exception applies.

11. Legal Bases Under EU GDPR and German DSGVO

Where the GDPR applies, we process personal data based on one or more of the following legal bases:

  • Consent, where you have given clear permission for a specific purpose.

  • Performance of a contract, where processing is necessary to enter into or perform a contract with you.

  • Legal obligation, where processing is necessary to comply with applicable law.

  • Legitimate interests, where processing is necessary for our legitimate business interests or those of a third party, provided your rights and freedoms do not override those interests.

  • Vital interests, where processing is necessary to protect someone’s life or safety.

  • Public interest, where processing is necessary for a task carried out in the public interest, where applicable.

Where we rely on legitimate interests, those interests may include responding to business inquiries, managing client relationships, improving services, protecting systems, preventing fraud, enforcing agreements, and developing our business.

12. German Specific Privacy Requirements

For individuals in Germany, this Privacy Policy also takes into account German privacy requirements, including the German Federal Data Protection Act and the Telecommunications Digital Services Data Protection Act.

In particular, we will request consent before using cookies, tracking pixels, analytics cookies, remarketing technologies, or similar tools that are not strictly necessary for the operation of the website, unless another legal exception applies.

German users may also contact the competent German data protection supervisory authority if they believe their personal data has been processed unlawfully. The German Federal Commissioner for Data Protection and Freedom of Information explains that individuals have the right to lodge complaints with a competent supervisory authority, and that Germany has federal and state data protection authorities with different areas of responsibility.

13. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our website, remember preferences, analyse website traffic, improve performance, enhance security, and support marketing activities.

  • Necessary cookies are used to make the website function properly and cannot usually be disabled without affecting the website.

  • Preference cookies remember settings such as language or region

  • Analytics cookies help us understand how visitors use the website.

  • Marketing cookies and tracking technologies may be used to deliver relevant content or advertisements and to measure campaign performance.

Where required by law, especially for EU and German users, we will request consent before placing non-essential cookies or using similar tracking technologies. You may withdraw or change your cookie consent at any time through our cookie settings tool, where available, or through your browser settings.

14. Analytics and Online Advertising

We may use analytics and advertising tools, including services such as Google Analytics, Google Ads, LinkedIn tools, Meta tools, or similar services.

These tools may collect information such as IP address, device information, pages visited, time spent on pages, referral source, cookie identifiers, and interaction data.

Where required by law, we will use these tools only after obtaining consent. We may also use IP anonymisation, consent mode, data processing agreements, and other safeguards where appropriate.

15. Marketing Communications

We may send newsletters, publications, event invitations, service updates, and other marketing communications where permitted by law or where you have consented.

You may unsubscribe from marketing communications at any time by using the unsubscribe option in our emails or by contacting us directly.

Even if you unsubscribe from marketing, we may still send service-related, contractual, administrative, legal, or transactional messages.

16. Disclosure of Personal Data

We may disclose personal data to the following recipients where necessary and lawful:

  • Sanet Group affiliated companies.

  • Employees, directors, officers, consultants, advisors, lawyers, accountants, auditors, recruiters, and authorised representatives.

  • IT providers, hosting providers, cloud service providers, email providers, analytics providers, marketing platforms, payment providers, document management providers, customer relationship management providers, translation providers, and administrative service providers.

  • Banks, insurers, auditors, tax advisors, legal advisors, business partners, suppliers, investors, potential buyers, joint venture partners, and transaction counterparties.

  • Government authorities, courts, regulators, tax authorities, labor authorities, immigration authorities, corporate registries, law enforcement authorities, and other public bodies.

  • Clients, employers, candidates, suppliers, representatives, or other persons where disclosure is necessary to provide requested services.

We require service providers who process personal data for us to protect the data and process it only for authorised purposes.

17. Data Processors

Where we use third-party processors, we will take reasonable steps to ensure that they process personal data only on our instructions, keep personal data confidential, apply appropriate security measures, assist with data subject requests where required, and delete or return personal data when the service ends, unless retention is legally required.

Where GDPR applies, we will use data processing agreements that meet GDPR Article 28 requirements.

18. International Transfers

Sanet Group is based in Thailand and may process personal data in Thailand. We may also transfer personal data to service providers, affiliated companies, clients, advisors, or authorities in other countries where necessary for the purposes described in this Privacy Policy.

Where personal data is transferred from the EU or Germany to Thailand or another country outside the EU/EEA, we will use appropriate safeguards where required. These safeguards may include Standard Contractual Clauses approved by the European Commission, transfer impact assessments, technical and organisational security measures, contractual commitments, explicit consent where legally valid, or another lawful transfer mechanism.

Where personal data is transferred from Thailand to another country, we will comply with applicable Thai PDPA cross-border transfer requirements.

19. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods depend on the type of data and the purpose of processing. For example, client records may be retained for the duration of the client relationship and any applicable legal limitation period. Accounting and tax records may be retained for the period required by law. Recruitment records may be retained for the recruitment process and a reasonable period afterwards, unless longer retention is permitted by consent or law.

When personal data is no longer required, we will delete, destroy, anonymise, or securely archive it.

20. Security

We use reasonable technical, organisational, and physical measures to protect personal data against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

These measures may include access controls, password protection, secure storage, confidentiality obligations, staff training, system monitoring, vendor controls, backup procedures, and document management controls.

No method of internet transmission or electronic storage is completely secure. We therefore cannot guarantee absolute security.

21. Your Rights Under Thai PDPA

Subject to applicable law, you may have the right to access your personal data, request a copy of your personal data, request correction, request deletion or anonymisation, object to processing, request restriction of processing, withdraw consent, request data portability, and lodge a complaint with the competent Thai authority.

We may ask you to verify your identity before responding to a request.

22. Your Rights Under GDPR and German DSGVO

Where the GDPR applies, you may have the following rights:

  • The right of access.

  • The right to rectification.

  • The right to erasure.

  • The right to restriction of processing.

  • The right to data portability.

  • The right to object to processing.

  • The right to withdraw consent at any time where processing is based on consent.

  • The right to object to direct marketing.

  • The right not to be subject to a decision based solely on automated processing, including profiling, where such a decision has legal or similarly significant effects.

  • The right to lodge a complaint with a competent data protection supervisory authority.

Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.

23. How to Exercise Your Rights

You may exercise your rights by contacting us at:

We will respond within the period required by applicable law. In some cases, we may refuse a request where permitted by law, such as where the request conflicts with legal obligations, rights of others, confidentiality duties, or the establishment or defence of legal claims.

24. Automated Decision Making

We do not intend to make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.

If this changes, we will provide additional information required by applicable law.

25. Children’s Privacy

Our website and services are generally intended for business users, clients, professionals, applicants, and adults. We do not knowingly collect personal data from children unless necessary for a lawful service and where appropriate consent or authorisation has been obtained.

If you believe that a child has provided personal data to us without proper authorisation, please contact us so that we can take appropriate action.

26. Third Party Websites

Our website may contain links to third-party websites, social media pages, payment platforms, partner websites, or external resources.

We are not responsible for the privacy practices, content, or security of third-party websites. Please review the privacy policy of any third-party website you visit.

27. Business Transactions

If Sanet Group or Sanet Holding Co., Ltd. is involved in a merger, acquisition, restructuring, joint venture, investment, financing, asset sale, or similar transaction, personal data may be disclosed or transferred as part of that transaction.

Where required by law, we will provide appropriate notice before personal data becomes subject to a materially different privacy policy.

28. Legal Disclosure

We may disclose personal data where we believe in good faith that disclosure is necessary to comply with law, respond to lawful requests, protect our rights or property, prevent fraud or misconduct, protect individuals, maintain security, or establish, exercise, or defend legal claims.

29. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, technology, or business operations.

The updated version will be posted on our website with a revised effective date. We encourage you to review this Privacy Policy periodically.

30. Governing Law

This Privacy Policy is governed by the laws of Thailand, unless mandatory data protection laws of another jurisdiction apply.

For individuals in the EU or Germany, mandatory rights under the GDPR, German BDSG, German TDDDG, and other applicable data protection laws remain unaffected.

31. Contact Us

For privacy-related questions, requests, or complaints, please contact:

Sanet Group under Sanet Holding Co., Ltd.

Connect

© Sanet Group (2025). All rights reserved.

2/1 Soi Rom Klao 25/2
Bangkok 10520, Thailand
+66 2 737 642-0
management@sanet.co.th
www.sanet-group.com
Business License
No. 0105548029419
Recruitment License
No. 1900/2567

2/1 Soi Rom Klao 25/2
Bangkok 10520, Thailand
+66 2 737 642-0
partner@sanet-legal.com
www.sanet-group.com
Business License
No. 0105560114781

2 Soi Rom Klao 25/2
Bangkok 10520, Thailand
+66 2 737 642-0
management@sanet.co.th
www.sanet-group.com
Business License
No. 0105543069391

2/1 Soi Rom Klao 25/2
Bangkok 10520, Thailand
+66 2 737 642-0
management@sanet.co.th
www.sanet-group.com
Business License
No. 0105567088611

Denk IT GmbH
An Der Aspe 7
36137 Großenlüder
Hessen, Germany
www.denkit.com
+49 661 250090-20