This policy explains what data TorbChat collects, what we use it for, who we share it with, how long we keep it, and how you can ask us to delete it.
1. About this policy
TorbChat (the "Service") is operated by IMAGELAND CO., LTD. ("we", "us") and is developed and technically operated on our behalf by RUBKIANCODE CO., LTD., our service provider. It brings conversations from channels such as LINE Official Account and Facebook Messenger into a single inbox for sales and support teams. This policy covers the web application, the mobile application, and the browser extension used to import past conversations. We comply with Thailand's Personal Data Protection Act B.E. 2562 (PDPA) and, where they apply, the GDPR and the CCPA.
We act in two roles:
- Team members' account data — we are the *data controller*.
- End customers' conversations arriving from the channels an organisation connects — that organisation is the *data controller* and we are the *data processor* acting on its instructions. If you are an end customer, contact the business you were messaging first; you may always contact us as well (section 11).
The Service is built for business use, is not directed at children, and we do not knowingly collect data from minors.
2. What data we collect
We collect data when you sign up, connect a channel, when your customers message you, and as your team uses the Service:
- Team accounts — the name, email, and profile picture from the external account used to sign in, your role in the organisation, and a device identifier for notifications. Regular team members sign in only through an external identity provider, so we store no passwords for these accounts (the sole exception is a temporary, access-restricted test account we provision solely for platform app review).
- End-customer data — the user identifier the platform issues, the display name and profile-picture link, the full content of the conversation, attachments (images, video, audio, files) which we download and store in our own systems, any location the customer shares, and message timestamps.
- Data your team enters — phone numbers, emails, notes, tags, lead stages, and content your team uploads.
- Technical data — the raw payload a platform delivers with each new message, error reports, and IP addresses in server logs.
We do not ask for sensitive data such as national ID numbers, health information, or payment-card details. If such information is typed into a conversation, it is stored as part of that message, and the controlling organisation decides whether to keep it.
3. Connected platforms
You grant access yourself when connecting a channel, and we use only what the shared inbox needs.
| Channel | What connecting it lets us do | Customer data we receive |
|---|---|---|
| LINE Official Account | Receive and reply to messages on the account's behalf; read the quota and statistics LINE provides; manage rich menus and broadcasts at your instruction. | The LINE user ID, name, profile picture, message content, and attachments. |
| Facebook Messenger (Pages) | See the Pages you manage so you can choose one; read and reply to that Page's messages; and have the Page deliver new messages to us. We do not access your personal profile, friends, posts, or ad accounts, and never post to the Page. | A Page-Scoped ID (not usable across Pages), the name and picture visible to the Page, message content, attachments, and shared locations. |
| Not available yet. | None. |
We comply with the terms of every platform we connect to, including the Meta Platform Terms and Developer Policies and the LINE Developers agreements. Platform data is used only to provide the Service to the organisation that owns the channel — never combined with other sources for advertising profiles, and never passed to data brokers.
4. How we use the data
We use the data to: deliver conversations between your team and your customers; coordinate the team (assignment, hand-over, alerts); keep searchable history; build customer records and sales reports; run the automation the organisation configures itself (auto-replies, assignment rules, broadcasts); and keep the Service secure.
We do not sell personal data, do not use it for advertising, do not build profiles to resell, and do not use conversation content to train AI models — no AI analysis of conversations currently runs in the Service at all.
5. How we share data
We may disclose data to service providers that work with us, only as far as running the Service requires. Each receives only what is described here and is bound by data-processing terms no weaker than this policy.
| Category of provider | What they receive, and why |
|---|---|
| Cloud infrastructure providers | The servers, database, and file storage the Service runs on — Service data resides on this infrastructure. |
| Sign-in provider | External-account sign-in — we receive the name, email address, and profile picture from that account. |
| Push-notification delivery | Delivery of push notifications to team members' phones — each carrying the contact's name and a message preview of at most 120 characters. |
| Error-monitoring provider | Application error reports — details of the failing request may be attached to a report. |
| The email provider your organisation configures | Alert emails about waiting chats — the chat name and a timestamp, never message content. |
| Development and technical operations provider | Building, maintaining, and troubleshooting the Service — its team can access data in the system only as far as resolving a problem requires, under a data processing agreement with us. |
| The messaging platforms your organisation connects | The messages your team sends to a customer, at your instruction. |
We run no behavioural analytics, no advertising pixels, and have no marketplace integrations. Beyond the above we disclose data only where the law requires it, under a court order, or to protect rights and safety. In a merger or transfer of the business, data may transfer with it, bound by a policy no weaker than this one.
6. Data retention
We keep data for as long as the organisation uses the Service — searchable history is one of its central purposes. When a channel is disconnected, its contacts, conversations, and messages are removed from the database immediately. There is currently no automatic time-based deletion, and stored media files are removed on request. Where a dispute or legal obligation exists we may keep what is necessary until it is resolved. You can request deletion at any time — see the data deletion instructions.
7. Your rights
Under the PDPA and comparable laws you may access and obtain a copy of your data, have it corrected, erased, or its use restricted, object to processing, withdraw consent, take your data elsewhere in a machine-readable form, and complain to the Personal Data Protection Committee.
To exercise any of these, write to rubkiancode@gmail.com. We acknowledge within 7 days and complete the request within 30 days of verifying your identity. If you are the end customer of a business using the Service, we coordinate with that business as your data controller.
8. Data security
Traffic is encrypted with HTTPS; platform tokens are encrypted (AES-256-GCM) before storage and never exposed through the interface or the API; regular team sign-in goes through an external identity provider, so no passwords are stored for regular team accounts; every request is checked server-side against organisation membership, so data cannot cross organisations; inbound platform messages are signature-verified, and media is readable only through signed links.
No system is completely secure. If a breach occurs that is likely to affect people's rights and freedoms, we will notify the affected organisations and the supervisory authority within the time the law requires.
9. International transfers
Our servers, and some providers listed in section 5, are located or process data outside Thailand, so using the Service involves cross-border transfers. We choose providers with adequate protection standards and rely on the contractual safeguards the law requires.
10. Cookies
We use just two cookies, both strictly necessary: a session cookie that keeps you signed in, and a language cookie. There are no analytics, advertising, or cross-site tracking cookies.
11. Contact and changes
For privacy questions, to exercise your rights, or to request deletion:
- Data controller: IMAGELAND CO., LTD.
- Address: 91 Soi Chalermphrakiat Ratchakan Thi 9, Dokmai, Prawet, Bangkok 10250
- Email: rubkiancode@gmail.com
- Website: https://www.imageautomat.com
- Developed and operated by: RUBKIANCODE CO., LTD.
We may update this policy as the Service changes or as the law requires — the current version always lives on this page with its effective date, and material changes are announced to users before they take effect. Detailed deletion steps are on the data deletion instructions page.