Privacy Policy

Effective Date: 20th May 2025

221b Limited or its affiliated companies if it has (“we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal information when you visit our website, use our services, or engage with us as a customer, partner, or software user — we may collect and process your data from the following purposes:

 

What personal information do we collect and why?

Contact Information

Your name, email, telephone number, company name, job title, or other contact details may be collected in order to respond to your inquiries, support requests, demo bookings, or any other service-related engagement. When you visit with this site, cloud and online services, software products, or online services operated by 221b Limited or its affiliated companies if it has. we may ask for this information to enable appropriate follow-up and communication. This information may be shared internally with relevant personnel—within 221b Limited and its associated group companies, where applicable—for the purpose of responding to your request or providing the requested service.

Business & Account Information

When you or your organization request a service from 221b Limited or any of its associated companies—such as scheduling a demo, initiating a trial, or engaging any other type of service—we may collect your business and account information. This includes details relating to your organization, system usage, contract history, or other relevant data necessary to fulfill our business obligations and deliver the requested services.

Financial & Payment Data

When you make a request to purchase products or services from 221b Limited or its affiliated companies if it has, we may collect the financial information necessary to process your payment securely. This may include your billing address, bank account details, credit or debit card numbers, expiration dates, security codes, and other relevant payment-related information. We implement appropriate technical and organizational safeguards—such as encryption and compliance with PCI-DSS standards—to protect this information during both transmission and storage.

Location & Technical Data

When you interact with this Site, cloud and online services, software products, view our content on certain third-party websites, or online services operated by 221b Limited or its affiliated companies if it has. we may collect information to support security, service optimization, analytics, content development, and targeted advertising. This may include location-related data such as your Internet Protocol (IP) address, internet tags, GPS coordinates, Wi-Fi signals, cellular network data, Bluetooth, Radio-frequency Identification (RFID), beacon technology, or other similar location-tracking technologies.

Cookies & Usage Tracking

We use cookies and similar tracking technologies to collect data about how you interact with our website, software products, cloud services, or when viewing our content on third-party websites or online platforms operated by 221b Limited or its affiliated companies, if applicable. This may include information such as time spent on pages, navigation behavior, connection type, and device activity—gathered through tools like cookies, web beacons, Local Storage, HTML5, and other online tracking technologies.

These tools help us personalize your experience, enhance website functionality, deliver more relevant content, improve performance, and support analytics and marketing initiatives. We may also use third-party cookies for these same purposes. Please note that if you choose to disable cookies or similar technologies, certain areas or features of our site may not function properly. For more details, please refer to our [Cookies Policy].

Email Interconnectivity

When you receive email communications from 221b Limited or any of its affiliated companies, we may use email tracking technologies to collect information about your interactions with our messages. This may include data on when you open an email, which links or banners you click, whether you forward the message, or take any follow-up actions—such as submitting a service request, scheduling a demo, or making a purchase.

This information helps us measure the effectiveness of our communications, improve future content, personalize your experience, and support our broader marketing and engagement strategies.

Employment

When you apply for a job opportunity or engage with 221b Limited or any of its affiliated companies as a candidate, contractor, or employee, we may collect and process personal data necessary to evaluate your application or manage your employment relationship. This information may include, but is not limited to, your full name, contact details, resume/CV, employment history, education background, professional qualifications, identification number, government-issued documents, references, and any other data you provide during the recruitment or onboarding process.

Where applicable, and as permitted by law, we may also collect sensitive personal data—such as health declarations or background checks—with your explicit consent or to comply with legal or regulatory obligations.

This data is used solely for legitimate human resource, administrative, legal, or compliance purposes, including recruitment evaluation, contract processing, payroll, employee benefits, and reporting to regulatory authorities.

Feedback, Support & Enquiries

When you contact 221b Limited or any of its affiliated group companies for feedback, support, or general inquiries—whether through our website, email, chat, or other communication channels—we may collect and process your name, email address, company affiliation, and other relevant contact information. We also collect the content of your message (e.g., support tickets, questions, feedback) along with associated metadata such as the date, time, and method of contact.

This information is used to respond to your request, improve our customer service, track support trends, resolve technical issues, and enhance the quality of our products and services. Communications may be stored for internal reference, audit purposes, or to support future interactions with you or your organization.

Mailing List Subscriptions

When you subscribe to receive newsletters, product updates, event invitations, or other communications from 221b Limited or any of its affiliated companies, we may collect your contact information, including your name, email address, organization name, and, where applicable, your postal address or country of residence.

We use this information to send you relevant updates based on your interests, your relationship with us, or the services you’ve engaged with. You may unsubscribe or update your communication preferences at any time by clicking the opt-out link in our emails or by contacting us directly.

We do not share your subscription data with third parties for marketing purposes unless we have your explicit consent.

Sensitive Personal Data

221b Limited and its affiliated group companies may collect and process sensitive personal data only when strictly necessary and in full compliance with applicable data protection laws.

Such data may be collected, for example, during job applications, regulated investigations, service-related requests in highly regulated sectors, or legal compliance scenarios. Sensitive personal data includes—but is not limited to—information regarding your: Racial or ethnic origin, Religious or philosophical beliefs, Political opinions, Trade union membership, Health or medical conditions, Genetic or biometric identifiers, Sexual orientation or sex life, Financial or criminal background (in specific regulated contexts), and / or other sensitive personal information data if applicable.

We will only process this type of data with your explicit consent, or where such processing is permitted or required by law, regulation, or court order. When consent is requested, we will provide clear information on the specific purpose of collection and your rights in relation to that data.

In addition to information you provide directly, we may also receive sensitive data about you from trusted third parties such as recruitment partners, legal advisors, regulatory authorities, affiliates, or publicly available sources—only where such collection is lawful and relevant to our engagement with you.

All sensitive data is treated with heightened security, confidentiality, and restricted access controls.

 

How We Use Your Personal Data

We use the personal information we collect—either directly from you or through your use of our services—for the following purposes:

• To provide you with access to our software and services, including demos, trials, licensing, or enterprise deployments;

• To manage and maintain our business relationship with you, including customer onboarding, account administration, payment processing, billing, compliance reporting, and technical support;

• To respond to your requests, such as inquiries, support tickets, feedback, or service-related issues;

• To personalize your experience across our websites, platforms, or communication channels, and deliver more relevant content and feature recommendations;

• To develop and improve our website, software products, cloud services, and business offerings, based on usage analytics, feature feedback, and support trends;

• To perform research, testing, and analysis, including product usage trends, demographic studies, and service performance evaluations;

• To determine your interests, preferences, and usage patterns, and to offer you targeted content or features; To notify you of updates, changes, or enhancements to our Site, services, or terms;

• To send you marketing communications, where legally permitted or with your explicit consent, including newsletters, product updates, event invites, or industry content relevant to your role or organization;

• To ensure the security, stability, and performance of our systems, including fraud prevention, audit logging, threat detection, and access control;

• To comply with our legal obligations, including financial reporting, data retention requirements, law enforcement cooperation, or regulated industry compliance (e.g., AML, KYC, financial crime standards);

• To maintain internal records, conduct compliance audits, support insurance or legal processes, and uphold contractual commitments;

• To exercise or defend our legal rights, protect users or systems, or comply with applicable laws, court orders, or regulatory directives;

• For any other purpose directly related to or reasonably necessary for the above, or as otherwise disclosed to you at the time your data was collected;

• Only with your explicit consent, for any additional purpose not outlined here but permissible under applicable data protection laws.

 

We rely on the following legal grounds for processing personal data:

• Performance of a contract with you or your organization;

• Compliance with a legal obligation to which we are subject;

• Our legitimate business interests, provided these are not overridden by your data protection rights;

• Your explicit consent, which can be withdrawn at any time;

• Protection of your vital interests or those of others;

• Tasks carried out in the public interest, particularly in regulatory or investigative contexts.

We do not sell or rent your personal data to third parties. We do not use your data for automated decision-making or profiling, except as explicitly described in this Privacy Policy and permitted under applicable law.

 

Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds, as permitted under applicable data protection laws, including Thailand’s PDPA, GDPR, and others:

• Contractual Necessity – To deliver the products or services you request, including software access, demos, onboarding, billing, support, and service communications.

• Consent – When you voluntarily opt in to receive marketing communications, participate in partner programs, or share information via public forums or directories. You may withdraw consent at any time.

• Legal Obligation – Where we are required to collect, retain, or disclose personal data in accordance with applicable laws or regulations, such as anti-money laundering (AML) or financial reporting requirements.

• Legitimate Interest – For purposes such as improving our services, maintaining security, preventing fraud, analyzing usage trends, and communicating with you about relevant product updates or features—provided these interests do not override your fundamental rights.

• Vital Interest or Public Interest – In exceptional cases, such as to protect an individual’s life, respond to emergencies, or assist law enforcement or regulatory bodies in the public interest.

 

Disclosure of Your Personal Information

We treat your personal information with care and confidentiality. However, under certain circumstances, 221b Limited and its affiliated companies may disclose your personal data to third parties as outlined below—always ensuring that such disclosures are lawful, proportionate, and aligned with your rights under applicable data protection laws.

Subsidiaries, Affiliates, and Group Companies

Your personal data may be shared internally across 221b Limited and its associated companies, including affiliates, subsidiaries, or any future acquisitions. This sharing supports internal business operations, product delivery, and centralized services.

If 221b Limited undergoes a business transition, such as a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring entity, subject to continued protection under this Privacy Policy.

Service Providers and Partners

We may share your personal data with third-party service providers who act on our behalf to help operate our website, platform, and services. This includes, but is not limited to:

• Cloud hosting and infrastructure partners

• CRM and email communication platforms

• Payment processors

• Marketing and analytics service providers

• Legal, audit, or compliance consultants

These providers are contractually bound to process your data securely, only as instructed, and not for their own use.

 

With Your Consent

We may disclose your personal information to unaffiliated third parties or business partners with your explicit consent—such as when you request to be introduced to a partner, register for a joint webinar, or participate in a collaborative event. You will always be given the opportunity to authorize such sharing.

Required by Law or to Protect Rights

We may disclose your personal data without your consent if required to:

• Comply with a legal obligation, subpoena, court order, or government request

• Investigate or prevent suspected fraud, security breaches, or illegal activities

• Enforce our legal rights, defend against claims, or protect the safety of users or the public

• Cooperate with regulators or law enforcement agencies under AML, financial, or compliance laws

Public Forums and Directories

If you choose to share personal data on public areas of our website—such as blog comments, user reviews, or community discussion boards—this information will be publicly visible and may be accessed or indexed by search engines. You submit such content at your own risk.

Additionally, if you register for a 221b-hosted event, community, or conference, you may be given the option to share your contact information with other attendees or participants. This is always subject to your consent.

Third Parties at Your Request

We may share your personal information with third-party providers of services or products that you have specifically requested, such as technology integration partners or solution vendors. This sharing is strictly limited to fulfilling your request.

 

Security of Your Personal Information

221b Limited and its affiliated companies are committed to protecting the confidentiality, integrity, and availability of your personal data. We implement industry-standard technical and organizational security measures designed to prevent your information from being accidentally lost, used, accessed, altered, or disclosed in an unauthorized way.

These safeguards include—but are not limited to—access controls, encryption protocols, secure server environments, role-based access management, staff training, and ongoing security awareness programs. Our systems undergo regular vulnerability assessments and third-party penetration testing to evaluate and strengthen our security posture.

Where applicable, we may follow internationally recognized standards such as ISO/IEC 27001 or SOC2 to ensure our information security management practices meet global benchmarks.

Our infrastructure and software services may be hosted on trusted third-party platforms (e.g., AWS, Azure, Huawei Cloud, Google Cloud), each selected based on their ability to comply with strong data protection frameworks and contractual safeguards, including Data Processing Agreements (DPAs) and Standard Contractual Clauses (SCCs).

While we apply strict controls and constant monitoring, no system can be guaranteed fully secure. Therefore, we cannot warrant the absolute security of your personal data in all circumstances.

The security of your information also depends on you. If you create an account or access restricted areas of our services, you are responsible for keeping your password and login credentials confidential.

In the event of a data breach or unauthorized access that may compromise your data, we will notify affected individuals and relevant regulators without undue delay, in accordance with applicable legal obligations.

 

Updating Your Personal Information

To help us keep your records accurate and up to date, we ask that you promptly notify 221b Limited or any of its affiliated companies if any of the personal information you have provided changes. For example, if your email address, job title, or organization details change—or if you wish to cancel a service request or correct any inaccuracies—you may contact us using the details provided in the Contact Us section of this Privacy Policy.

To protect your privacy and ensure data integrity, we may request verification of your identity before processing any changes to your personal data. This may include requesting supporting documentation or confirming your request through a known contact channel.

Please note that we rely on the accuracy and completeness of the data you provide. 221b Limited is not liable for any issues, service disruptions, or damages that result from incorrect, outdated, or incomplete personal information submitted by you.

 

International Data Transfers

As a global company, 221b Limited and its affiliated companies may transfer your personal data across borders to support international operations, provide technical infrastructure, and deliver services efficiently. This may include transfers to jurisdictions that do not provide the same level of data protection as your home country.

To help ensure that your data remains protected during such transfers, we rely on recognized legal mechanisms, which may include:

• Standard Contractual Clauses (SCCs) issued or approved by relevant regulatory authorities (e.g., the European Commission)

• Binding Corporate Rules (BCRs) adopted by group entities, where applicable

• Adequacy decisions, where the destination country has been formally recognized as providing adequate data protection

• Your explicit consent, where required by applicable law

Where appropriate, and as required by applicable regulations, we may also consider additional safeguards—such as encryption or access controls—to help maintain the confidentiality, integrity, and security of your data.

 

Data Retention

221b Limited and its affiliated companies retain your personal data only for as long as necessary to fulfill the purposes for which it was collected—whether to provide services, comply with legal or regulatory requirements, resolve disputes, protect our rights and assets, or enforce contractual obligations.

We maintain data retention policies aligned with the type of information, the nature of our relationship with you, and applicable laws. This means that the length of time we keep your data may vary depending on whether it relates to a commercial transaction, support request, product usage, job application, or legal matter.

When there is no longer a legitimate business or legal reason to retain your personal information, we will securely delete, anonymize, or destroy it in accordance with our internal data disposal procedures and applicable laws.

 

Your Privacy Rights

Depending on your location, you may have rights to: 

To exercise these rights, contact: [email protected]

 

Children’s Privacy

Our website, software, and services are not intended for individuals under the age of 18. 221b Limited and its affiliated companies do not knowingly collect, use, or solicit personal information from children under 18 years of age.

If you are under 18, please do not use or provide any personal information through our Site, software, or any associated platforms. This includes submitting forms, creating accounts, making inquiries, or interacting with any public features of the services.

If we become aware that personal data has been collected from a child under 18 without verified parental or legal guardian consent, we will take immediate steps to delete such information from our systems.

We encourage parents and guardians to monitor their children’s internet usage and to help enforce this policy by instructing children never to share personal information online without their permission.

 

Links to Other Site

Our website, software, and related services may contain links to third-party websites, platforms, applications, or embedded content not operated or controlled by 221b Limited or its affiliated companies. These links are provided for convenience or informational purposes only.

Once you click on a third-party link, you will be redirected to an external site. We strongly advise you to review that site’s own privacy policy and terms of use. The presence of a link does not imply endorsement by 221b Limited of the third party or its offerings.

We do not control and are not responsible for:

• The accuracy, legality, or reliability of third-party content;

• The privacy, security, or data collection practices of external sites;

• Any personal information you provide directly to third-party services or that may be automatically collected when you interact with third-party features embedded on our platform.

Any personal data collected by those third parties will be governed by their respective privacy policies and not by this Privacy Policy.

 

Data Security

221b Limited and its affiliated companies are committed to protecting your personal data through a combination of physical, administrative, and technical safeguards. Our security practices include:

• End-to-end encryption for data in transit and at rest

• Access control, user authentication, and role-based permissions

• System logging, audit trails, and anomaly detection

• Regular vulnerability assessments and third-party penetration testing

• Ongoing staff training on privacy and security best practices

We also assess our infrastructure providers and vendors to ensure they meet industry security and compliance standards.

While we apply rigorous safeguards, no security system is impenetrable. In the unlikely event of a data breach that may affect your personal data, we will notify you and any relevant regulatory authority in accordance with applicable legal requirements.

 

Updates to This Policy

We may revise or update this Privacy Policy from time to time to reflect changes in our operations, legal obligations, or technology. When we do, we will update the “Effective Date” at the top of this page.

While we may choose to notify you of significant changes, we are not obligated to do so. We encourage you to check this page periodically to stay informed about how we collect, use, and protect your personal information.

Your continued use of our website or services after any updates constitutes your acceptance of the revised Privacy Policy.

 

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal data is handled, you may contact us at: 221b Limited Email: [email protected]

If you wish to exercise any of your data protection rights under applicable laws—such as accessing your personal information, correcting inaccuracies, or requesting deletion—you may submit your request via email. To help us verify and process your request efficiently, please include the following:

• Sufficient information to identify you (e.g., full name, email address, organization name, or reference number if applicable);

• A description of the specific request or right you wish to exercise;

• Proof of identity and address, such as a copy of your passport, national ID card, or driver’s license (for verification purposes only).

We will use this information solely to verify your identity and process your request securely. If we are unable to verify your identity or authority to act on behalf of someone else, we may not be able to fulfill your request.

Please note that depending on your jurisdiction (e.g., under CCPA or GDPR), there may be limits to how frequently such requests can be submitted within a given timeframe (e.g., twice within a 12-month period for certain data access requests).