Last Updated: October 25, 2025
Cookie Policy
TrueCode Co., Ltd.
This Cookie Policy explains how TrueCode Co., Ltd. ('we', 'us', or 'our') uses cookies and similar tracking technologies on our website and services in compliance with the Personal Data Protection Act B.E. 2562 (2019) ('PDPA').
1. Introduction and Scope
TrueCode Co., Ltd. is committed to protecting your privacy and ensuring transparency in our data processing activities. This Cookie Policy forms part of our comprehensive Privacy Policy and explains our use of cookies and similar technologies across our digital platforms. This policy applies to all users of our website, applications, and services, regardless of location, with specific compliance measures for users in Thailand under the PDPA.
Applicable Services:
- AI Chat Bot platform and related services (orca.truecode-ai.in.th)
2. Definitions
For the purposes of this Cookie Policy, the following terms shall have the meanings set forth below:
Cookies
Small text files containing alphanumeric identifiers that are downloaded to your device when you visit our website, enabling recognition of your device on subsequent visits.
Personal Data
As defined under the PDPA, any information relating to an identified or identifiable natural person, including but not limited to device identifiers, IP addresses, and behavioral data.
Processing
Any operation performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, or combination.
Data Controller
TrueCode Co., Ltd., as the entity that determines the purposes and means of processing personal data through cookies.
Consent
Freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your personal data.
5. Legal Basis for Processing Under PDPA
Our cookie processing activities are based on the following legal grounds under the PDPA:
Consent
For analytics and marketing cookies, we obtain your explicit, informed consent through our cookie banner.
Applies to: Non-essential cookies including analytics, marketing, and advanced personalization features.
Contract Performance
For cookies necessary to provide services you have requested or to perform our contractual obligations.
Applies to: Essential cookies required for service delivery and user authentication.
Legitimate Interest
For cookies necessary for our legitimate business interests, where such interests are not overridden by your fundamental rights.
Applies to: Security cookies, basic functionality cookies, and fraud prevention measures.
6. Cookie Consent and User Rights
In compliance with the PDPA, we implement comprehensive consent management mechanisms:
6.1 Consent Collection
- Clear and prominent cookie banner with detailed information
- Granular consent options for different cookie categories
- Easy-to-understand language avoiding technical jargon
- Opt-in mechanism for non-essential cookies (no pre-ticked boxes)
- Ability to provide partial consent (accept some cookie categories while declining others)
6.2 Your Rights Under PDPA
Right to Withdraw Consent
You may withdraw your consent at any time
Right to Access
You may request information about the personal data we process through cookies.
Right to Rectification
You may request correction of inaccurate personal data collected through cookies.
Right to Erasure
You may request deletion of your personal data subject to legal and contractual obligations.
Right to Data Portability
You may request your personal data in a structured, commonly used format.
7. Third-Party Services and Data Sharing
We work with carefully selected third-party service providers who may process personal data collected through cookies. All such arrangements are governed by data processing agreements that ensure PDPA compliance.
8. Data Retention and Deletion
We retain personal data collected through cookies only for as long as necessary to fulfill the purposes for which it was collected, subject to legal, regulatory, and business requirements:
Retention Schedule:
| Category | Period | Rationale |
|---|---|---|
| Essential Cookies | Duration of session or up to 12 months for persistent authentication | Technical necessity for service provision |
| Functional Cookies | Up to 12 months or until consent withdrawal | User experience optimization and preference retention |
| Analytics Cookies | Up to 12 months or until consent withdrawal | Statistical analysis and service improvement |
| Marketing Cookies | Up to 12 months or until consent withdrawal | Marketing campaign effectiveness and audience development |
Deletion Procedures:
- Automated deletion upon expiry of retention periods
- Manual deletion upon user request or consent withdrawal
9. Security Measures
We implement comprehensive technical and organizational measures to protect personal data processed through cookies:
Technical Measures:
- Encryption of data in transit and at rest
- Secure cookie attributes (HttpOnly, Secure, SameSite)
- Regular security assessments and vulnerability testing
- Access controls and authentication mechanisms
- Data loss prevention (DLP) systems
Organizational Measures:
- Staff training on data protection and privacy
- Regular privacy impact assessments
- Incident response and breach notification procedures
- Third-party due diligence and monitoring
10. Policy Updates and Notification
We may update this Cookie Policy from time to time to reflect changes in our practices, legal requirements, or business operations. We will:
Update Process:
- Post the updated policy on our website with a new effective date
- Notify users of material changes through prominent website notices
- Send email notifications to registered users for significant changes
- Maintain an archive of previous policy versions for transparency
- Re-obtain consent where required by law for material changes
Important Notice: We encourage you to review this Cookie Policy periodically. Your continued use of our services after changes become effective constitutes acceptance of the updated policy, except where additional consent is required by law.
11. Compliance and Legal Framework
This Cookie Policy is designed to ensure compliance with applicable privacy laws and regulations, including but not limited to:
Applicable Laws & Regulations:
- Personal Data Protection Act B.E. 2562 (2019) of Thailand
12. Contact Information
For questions, concerns, or requests related to this Cookie Policy please contact:
Contact Us
Email: truecodecompany@gmail.com
Phone: (+66) 88-924-7944
Address: Casa Condo @MRT Sam Yaek Bang Yai Room No. 99/486, 25th Floor Nonthaburi 11140, Thailand