นโยบายความเป็นส่วนตัว - มาตรฐานการรักษาความปลอดภัยข้อมูล Fiwfan
Privacy Policy — Fiwfan.app
This Privacy Policy explains what personal data Fiwfan.app collects, why, on what legal basis, who it is shared with, how long it is kept, and what rights you have. It should be read together with our Terms of Use and Community Guidelines.
1. Who we are
Fiwfan.app ("we", "us", "the Website") are the data controller for the personal data described in this Policy.
2. Who this Policy covers
This Policy applies to:
- Members — anyone who registers an account
- Advertisers — Members who publish a Directory Listing
- Reviewers — Members who post reviews, photographs or comments
- Visitors — anyone who browses the Website without an account
Different sections apply to different groups; we say which where it matters.
3. What we collect
3.1 Information you give us when you register
Username, email address, password (stored hashed, never in
readable form), country or region, and date of birth or age
confirmation.
3.2 Information Advertisers provide for a Directory
Listing
Display name, listing text, photographs, service categories,
location at province and district level, contact details you
choose to publish, pricing information, and availability.
3.3 Verification data
Photographs taken for the purpose of confirming that the person in
a listing is the person operating the account. This may include a
photograph of you holding a device displaying the Fiwfan.app
interface, and where necessary an image of an identity document.
3.4 Reviews, comments and messages
Content you post publicly, and messages you exchange with other
Members through the Website.
3.5 Payment data
Where you pay for a Service or receive a reward payment:
transaction amount, currency, date, transaction reference, the
payment method type, and any wallet address or account identifier
you supply for receiving payments.
We do not receive or store full card numbers. Card payments are processed by our payment providers, who receive your card details directly.
3.6 Technical data
IP address, browser and device type, operating system, referring
URL, pages viewed, timestamps, and cookie identifiers. Server
access logs record requests made to the Website.
3.7 Reports and moderation records
Reports you submit about other users or content, reports others
submit about you, and the records of our decisions.
4. Data revealing sex life or sexual orientation
Some information published on Fiwfan.app may reveal, or allow inferences about, a person's sex life or sexual orientation. Under the GDPR this is a special category of personal data, and under the Thai PDPA it is sensitive personal data. Both require a higher standard of protection.
We process this data only on the basis of your explicit consent, given when you create a listing or post content of this kind. You may withdraw that consent at any time by deleting the content or closing your account, using the process in section 10. Withdrawal does not affect processing carried out before withdrawal.
We do not use this data for advertising, profiling, or any purpose other than operating the Website.
5. Why we process your data, and on what legal basis
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating and running your account | 3.1 | Performance of a contract |
| Publishing your listing or reviews | 3.2, 3.4 | Performance of a contract |
| Publishing content revealing sex life or sexual orientation | 3.2, 3.4 | Explicit consent (see section 4) |
| Verifying identity and age | 3.3 | Legal obligation; substantial public interest in preventing harm to minors; legitimate interests in preventing impersonation and fraud |
| Taking payment and paying rewards | 3.5 | Performance of a contract; legal obligation (tax and accounting records) |
| Moderation, safety, and handling reports | 3.4, 3.6, 3.7 | Legitimate interests in maintaining a lawful and safe platform |
| Security, fraud prevention, abuse detection | 3.6 | Legitimate interests in protecting the Website and its users |
| Establishing, exercising or defending legal claims, including enforcing rights in content published on the Website | 3.2, 3.3, 3.4, 3.6 | Legitimate interests in protecting our rights and those of our users; Article 9(2)(f) where special-category data is involved |
| Responding to your support requests | Any | Performance of a contract; legitimate interests |
| Complying with law enforcement or regulatory requests | Any | Legal obligation |
Where we rely on legitimate interests, we have assessed those interests against your rights and freedoms. You may object to that processing under section 10.
6. What is public, and what that means
This is the most important section of this Policy. Please read it carefully.
6.1 Directory Listings, profile pages, display names, listing photographs, verification photographs displayed on a listing, reviews, review photographs, and location at province and district level are published publicly. They can be viewed by anyone, with or without an account, from any country.
6.2 Public pages are indexed by search engines such as Google. They may appear in search results and in search engine caches, and may remain visible in those caches for a period after you delete them from Fiwfan.app. We do not control search engine caches, but we will assist you in requesting their removal.
6.3Third parties may copy public content without our permission. Our Terms of Use prohibit automated extraction, scraping and republication of content from the Website, and we take active steps against unauthorised copies — including takedown notices to hosting providers, search engines, CDNs and domain registrars. We cannot, however, guarantee that content published publicly will not be copied.
6.4 The following are never published: your email address, your password, your identity documents, your payment details, your IP address, and private messages.
7. Who we share data with
We share personal data only with the following categories of recipient, and only as necessary:
| Recipient | Purpose |
|---|---|
| Hosting and infrastructure providers | Operating the Website and storing data |
| Content delivery and security providers | Serving images and pages, protecting against attacks |
| Payment service providers | Processing payments and reward payouts |
| Email and messaging providers | Sending account and support emails |
| Analytics providers | Understanding how the Website is used |
| Professional advisers | Legal and accounting advice |
| Law enforcement, regulators, courts | Where legally required, or to establish or defend legal claims |
| Search engines, hosts, registrars and dispute-resolution bodies | Only in connection with enforcing rights in content published on the Website, and only the material necessary to substantiate the claim |
We do not sell personal data. We do not share personal data with advertisers or data brokers.
8. How long we keep data
| Data | Retention |
|---|---|
| Account data | For as long as your account is open, then [12] months |
| Published listings, reviews and photographs | Until you delete them or your account closes, then removed from public display; see 8.1 |
| Verification photographs displayed on a listing | As for published content |
| Payment and transaction records | [7] years, as required by tax and accounting law |
| Server access logs | [12] months |
| Moderation and report records | [24] months after the report is closed |
| Records relating to an active or anticipated legal claim | Until the claim is finally resolved, plus the applicable limitation period |
9. International transfers
We operate internationally. Your data may be stored or processed in the European Economic Area, Thailand, Singapore, and the United States.
Where we transfer personal data out of the EEA to a country without an adequacy decision, we use the European Commission's Standard Contractual Clauses, together with any additional safeguards required. Where we transfer personal data out of Thailand, we rely on the mechanisms permitted under the PDPA.
10. Your rights
Subject to the conditions in applicable law, you have the right to:
- Access — obtain a copy of the personal data we hold about you
- Rectification — have inaccurate data corrected
- Erasure — have your data deleted
- Restriction — have processing limited while a dispute is resolve
We do not charge for these requests and we will not restrict your account for making one.
11. Impersonation and unauthorised use of your images
If your photograph or information has been published on Fiwfan.app by someone else:
- Copy the link to the profile or listing
- Note the display name shown
We will review promptly and remove confirmed impersonation. We may ask for a verification photograph to confirm that you are the person depicted — this is to prevent the reporting process itself being abused to remove other people's legitimate listings.
12. Cookies
We use:
- Strictly necessary cookies — login sessions, security, load balancing. These cannot be disabled.
- Functional cookies — language and display preferences.
- Analytics cookies — aggregate usage statistics. Set only with your consent.
13. Security
We use encryption in transit (HTTPS), hashed password storage, access controls limiting staff access to what their role requires, and logging of administrative actions.
No system is completely secure. If a breach occurs that is likely to result in a risk to your rights, we will notify the relevant supervisory authority within 72 hours and notify affected users where the law requires it.
14. Children
Fiwfan.app is strictly for adults. You must be 18 or older to register, and verification includes age confirmation. We do not knowingly collect data from anyone under 18. If we learn that we hold such data, we delete it immediately and terminate the account.
If you believe a minor is using the Website, report it immediately. We treat these reports as our highest priority and will refer them to the appropriate authorities.
15. Automated decision-making
We do not make decisions producing legal or similarly significant effects about you solely by automated means. Automated tools may flag content or accounts for review, but suspension, removal and verification decisions are made by a person.
16. Direct marketing
We send service messages relating to your account, which you cannot opt out of while your account is open.
We send marketing messages only with your consent.
17. Changes to this Policy
We may update this Policy. The current version and its effective date always appear at the top, and previous versions are listed below. Where a change materially affects your rights, we will notify you directly using the contact details on your account before it takes effect.
18. Relationship to other documents
This Policy sits alongside our Terms of Use and Community Guidelines. Where a conflict arises about the handling of personal data, this Policy prevails.