Privacy Policy

apgame Co., Ltd. ("apgame", "we", "us", or "our") respects your privacy and is committed to protecting personal data in accordance with applicable data protection laws, including Thailand's Personal Data Protection Act B.E. 2562 (2019) ("PDPA").

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you visit our website, contact us, communicate with our team, or otherwise interact with apgame.

Note: This policy applies to apgame's website and general business communications. Specific projects, platforms, products, or services may be subject to additional privacy notices, data processing agreements, or contractual terms.

1. Who We Are

apgame is a technology company providing services including software engineering, AI and automation, business and mission-critical systems, data and integration, and resilience-related technology services.

For privacy-related requests, please contact:

• Company: apgame Co., Ltd.
• Email: contact@apgame.co

2. Personal Data We May Collect

Depending on how you interact with us, we may collect the following categories of personal data.

2.1 Information You Provide Directly

This may include:

• name and surname
• company or organization name
• job title or role
• email address
• telephone number
• information submitted through contact forms
• project requirements or business inquiries
• messages, files, or other information you send to us
• event, meeting, or consultation details
• recruitment information, if you apply to work with us

2.2 Technical and Usage Information

When you visit our website, we may automatically collect information such as:

• IP address
• browser type and version
• device type
• operating system
• referring URL
• pages viewed
• time and date of access
• interaction and navigation data
• cookie identifiers and similar technologies
• diagnostic, security, and performance information

2.3 Information From Third Parties

We may receive information from third parties where permitted by law, including:

• business partners
• service providers
• analytics providers
• advertising or marketing platforms
• social media platforms
• publicly available business sources
• clients or prospective clients who refer you to us

3. How We Use Personal Data

We may process personal data for the following purposes:

• to respond to inquiries and contact requests
• to understand business requirements and potential projects
• to prepare proposals, quotations, demonstrations, or consultations
• to provide and manage our services
• to communicate with clients, partners, suppliers, and prospective clients
• to manage contracts, billing, and business administration
• to operate, maintain, secure, and improve our website
• to analyze website usage and performance
• to protect against fraud, abuse, cybersecurity threats, and unauthorized access
• to maintain business records and comply with legal obligations
• to manage recruitment and employment-related inquiries
• to send business updates or marketing communications where permitted
• to establish, exercise, or defend legal claims
• to improve our products, services, processes, and customer experience

We will not use personal data for purposes that are materially incompatible with the purposes described above unless permitted or required by law.

4. Legal Bases for Processing

Where required by the PDPA or other applicable law, we rely on one or more lawful bases for processing personal data, including:

4.1 Contractual Necessity

Where processing is necessary to:

• take steps at your request before entering into a contract
• perform a contract with you or your organization
• manage a client, supplier, or partner relationship

4.2 Legitimate Interests

We may process personal data where necessary for legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms.

Examples include:

• responding to business inquiries
• maintaining website security
• improving our services
• preventing fraud
• managing business relationships

4.3 Consent

Where required, we may request your consent before processing personal data, including for certain marketing activities, analytics technologies, or cookies.

You may withdraw consent at any time, subject to applicable law.

4.4 Legal Obligations

We may process personal data where necessary to comply with legal, regulatory, tax, accounting, or other obligations.

5. Cookies and Similar Technologies

Our website may use cookies, pixels, local storage, analytics tools, and similar technologies to:

• operate essential website functions
• remember settings and preferences
• understand how visitors use the website
• measure performance
• improve content and user experience
• support security and fraud prevention
• support marketing or campaign measurement where permitted

Where required by law, non-essential cookies will only be used after obtaining appropriate consent.

You may manage cookies through your browser settings or any cookie preference controls made available on the website.

6. How We Share Personal Data

We do not sell personal data.

We may disclose personal data where reasonably necessary to:

• affiliated entities or members of our corporate group, if applicable
• hosting, cloud, infrastructure, analytics, communications, and software providers
• professional advisers such as lawyers, accountants, auditors, and insurers
• subcontractors and implementation partners working on authorized projects
• payment, billing, or financial service providers
• regulators, law enforcement authorities, courts, or government agencies where legally required
• parties involved in a merger, acquisition, restructuring, financing, or transfer of business assets
• other parties where you have authorized or requested the disclosure

Where third parties process personal data on our behalf, we seek to use appropriate contractual, organizational, and security safeguards.

7. Client Projects and Data Processing Roles

In some engagements, apgame may process personal data on behalf of a client as a data processor rather than as the data controller.

For example, this may occur when we:

• develop or operate a client platform
• migrate client data
• integrate enterprise systems
• maintain or support client applications
• process data within automated workflows
• deploy AI-enabled systems using client-controlled data

In those cases, the client's privacy notice and instructions may govern the relevant processing, and apgame will process the data in accordance with the applicable agreement and lawful instructions.

8. AI and Automated Systems

Some apgame services may involve artificial intelligence, machine learning, automation, or third-party AI services.

Where personal data is processed through such systems, we aim to apply appropriate safeguards based on the nature and risk of the use case, which may include:

• access controls
• human review
• data minimization
• logging and auditability
• contractual restrictions
• security controls
• retention controls
• restrictions on use of sensitive or confidential information

Specific AI-related processing may be governed by separate client agreements or project documentation.

9. International Transfers

Some of our service providers or technology infrastructure may process or store personal data outside Thailand.

Where personal data is transferred internationally, we will take steps required by applicable law to provide an appropriate level of protection, which may include contractual safeguards, adequacy mechanisms, consent, or other lawful transfer mechanisms.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• provide services
• maintain business and project records
• meet contractual obligations
• comply with tax, accounting, legal, or regulatory requirements
• resolve disputes
• enforce agreements
• protect our legitimate business interests

Retention periods may vary depending on the type of data, nature of the relationship, applicable law, and contractual obligations.

When personal data is no longer required, we will delete, anonymize, or securely dispose of it as appropriate.

11. Security

We use reasonable technical and organizational measures designed to protect personal data against:

• unauthorized access
• unlawful disclosure
• accidental loss
• alteration
• destruction
• misuse

Security measures may include, where appropriate:

• access controls
• role-based permissions
• authentication
• encryption
• logging and monitoring
• secure development practices
• backup and recovery procedures
• infrastructure security controls

No system is completely secure, and we cannot guarantee absolute security of information transmitted or stored electronically.

12. Your Rights

Subject to the PDPA and other applicable laws, you may have rights including the right to:

• request access to your personal data
• request a copy of your personal data
• request correction of inaccurate or incomplete data
• request deletion or destruction of personal data
• request restriction or suspension of processing
• object to certain processing
• request data portability where applicable
• withdraw consent where processing is based on consent
• lodge a complaint with the competent data protection authority

Some rights may be subject to legal exceptions or conditions.

To exercise your rights, contact us using the information in Section 1. We may need to verify your identity before processing a request.

13. Marketing Communications

Where permitted by law, we may send communications about:

• apgame services
• technology insights
• events
• case studies
• business updates

You may unsubscribe from marketing communications at any time by using the unsubscribe method provided in the communication or by contacting us.

Administrative, contractual, or service-related messages may still be sent where necessary.

14. Children's Privacy

Our website and services are primarily intended for businesses and professional users.

We do not knowingly collect personal data from children where parental or legal guardian consent is required by law.

If you believe that a child has provided personal data to us inappropriately, please contact us so that we can take appropriate action.

15. Third-Party Websites and Services

Our website may contain links to third-party websites, applications, or services.

We are not responsible for the privacy practices, security, availability, or content of those third parties. You should review their privacy policies before providing personal data.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes in our services
• changes in technology
• changes in business practices
• legal or regulatory requirements

The latest version will be published on this page with the updated effective date.

Material changes may be communicated through additional notices where appropriate.

17. Contact Us

If you have questions, requests, or concerns regarding this Privacy Policy or our handling of personal data, please contact:

apgame Co., Ltd.

• Email: contact@apgame.co

Last updated: 31 August 2026