Privacy Policy

ComLeadly (operated by บริษัท ธนากุลชูการ์มิ้ว จำกัด / Thanakul Sugar Milk Co., Ltd. — Thai juristic person, registration no. 0105566054152) is a software service for small business owners in Thailand who sell through their own Facebook Pages. Each Customer connects their own Page to our service. By using our website or service, you acknowledge this policy.

1.What the service does

With the Page owner's permission, we receive a notification when someone comments on the connected Page. We read those comments and automatically publish a reply on the Page, on the owner's behalf, in Thai, based on the product information and rules the owner sets up themselves. Replies are generated automatically, including with AI. When the owner enables it, we can also send a private Messenger reply to the person who commented. Owners can also schedule posts to their own Page and see a summary of their own Page's comment and message activity.

2.Data we access (only Pages the Customer connects)

• New comments on the connected Page's posts (text, commenter name/ID, post context)
• Incoming Messenger messages sent to the connected Page
• The connected Page's post data, only as needed to generate a relevant reply

We access this only via the permissions the Customer grants through Facebook, and only for Pages the Customer owns or manages.

3.What we store — and do not store

We store: the service-generated reply text and reply status; credit/usage counters and aggregate statistics (e.g. number of replies per day); comment IDs and timestamps (to avoid duplicate replies); the Page access token (stored encrypted, used only to read and reply on the connected Page).

End-customers' raw message text: we keep it for at most 90 days, then the system automatically deletes it every day in order of the date recorded, oldest first.

4.Retention and deletion

Comment-level records are automatically deleted within 90 days. The Page access token is deleted immediately when the Customer disconnects their Page (see Data Deletion).

5.Sharing and third-party providers

We do not sell and do not share personal data with third parties. We use the Facebook Graph API (to read and reply), an AI provider to generate replies (only the minimum necessary text is sent), and an email provider (Brevo) solely to send notifications to Customers — or where required by law.

6.Website data (sign-up form and cookies)

When you submit a sign-up or contact form on our website, we collect the details you provide (e.g. name, page name, email, phone, Line ID, shop information) to contact you and provide the service. The website uses cookies and the Facebook Pixel to measure and improve advertising. You can disable or delete cookies through your browser settings.

7.Data roles and your rights (Thai PDPA)

For the data of people who comment on or message a Customer's Page: the Customer (Page owner) is the Data Controller, and ComLeadly is the Data Processor acting on the Customer's instructions. Page data is used only to provide this service to that same Page's owner, and each business can see only their own Page's data.

As a data subject, you have the right to: access or obtain a copy; correct; delete or destroy; object to or restrict processing; withdraw consent; disconnect the Page at any time; and lodge a complaint with the regulator. To exercise these rights, contact us using the details below.

8.Security and changes to this policy

We use appropriate measures to protect data (e.g. token encryption), but no system is 100% secure, so we continuously improve our safeguards. We may update this policy from time to time, showing the "Last updated" date at the top.

9.Contact us