Effective on May 25, 2018

Navatas Hospitality Co., Ltd, dba “Smiling Tuk Tuk” is committed to maintaining and safeguarding the privacy of the information you share with us through our website. This policy outlines our handling practices and how we collect and use the Personal Data you provide during your online and offline interactions with us.

Owner and Data Controller

Navatas Hospitality Co., Ltd – 203 Srihaburanukit Road, Minburi, Bangkok, Thailand 10510
Owner contact email: info@navatas.com

What is personal data we collect ?

As used in this Privacy Policy, ”Personal Data“ means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, country of origin, credit or debit card number, phone number, nutrition preferences, cookie and data usage.

How do we use or disclose it ?


Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.

The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries (Paypal) handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.


Booking Information

Smiling Tuk Tuk may collect, use or disclose your personal data, either directly or through our agency and booking partners, for the purposes of offering or booking travel services on your behalf, such as your name, age, address, phone number, e-mail address, emergency contact information, passport information, travel medical information (where required), insurance details, ISIC information (where applicable), nationality, residency, nutrition preferences, trip evaluations, travel and accommodation preferences, comments you provide us, trip destination information, and payment-related information. This personal data enables us to provide you with trip information, accommodations, process payments, and provide similar travel services.

If you book a Smiling Tuk Tuk trip, we may rely on local service providers. Please be aware that Smiling Tuk Tuk may be required to provide certain personal data to our service providers for the purposes of delivering your experience. Therefore, when you book travel services with us, you consent to collection, use and disclosure of your personal data by Smiling Tuk Tuk—and the corresponding collection and use by the relevant travel partners or suppliers—for the purposes of administering and delivering the travel services you requested.

Your personal data may also be used for the purposes of:


  • Enabling us to better understand your needs as a customer and determine eligibility for our products and services;
  • Informing you about our products and services, or those of our partners that we believe may be of interest to you (provided that we have received valid consent from you, if such consent is required)
  • Providing ongoing service and support, including resolution of any issues with the services or products you request from Smiling Tuk Tuk
  • Ensuring the safety and security of our passengers and products
  • Carrying out internal accounting and administration of our business
  • Complying with laws, regulations, and immigration requirements.

Contests and Newsletters

We may also collect personal data, including contact information such as name, address, and phone number or email address if you elect to enter a contest or sweepstakes with us, subscribe to our newsletter, or request a brochure. We use this personal data for the purposes of administering the contests/sweepstakes or delivering the information you request.


The services contained in this section enable Smiling Tuk Tuk to monitor and analyze web traffic and can be used to keep track of User behavior. Smiling Tuk Tuk use personal data for Display Advertising extension for Google Analytics, Facebook Ads conversion tracking, Google AdWords conversion tracking, Google Analytics and WordPress Stats

Displaying content from external platforms

This type of services allows you to view content hosted on external platforms (Google Map, YouTube) directly from the pages of this Application and interact with them. This type of service might use cookie and still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.


Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.


In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.



The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.



  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.


Website Policies and Cookies

Our website uses a technology called a “cookie,” which is a small element of data that our website can send to your browser to be stored on your computer so that we can recognize your computer when you return. If you have registered with our website, cookies may provide us and our service providers with information that we will use to personalize our website in accordance with your preferences. Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. If you decide not to accept cookies from our website, you may not be able to take advantage of all of its features.


Third Party Cookies

Third party vendors show Smiling Tuk Tuk’s ads across the internet. These third party vendors use cookies to serve ads based on a user’s prior visits to our website. You can opt out of third-party usage of cookies for advertising purposes by visiting the Network Advertising Initiative opt-out page available at: http://www.networkadvertising.org/choices/.

We may also use a third party to help us gather and analyze information about the areas that you visit on the website to evaluate and improve the customer experience and the convenience of the website, and to help us evaluate some of the specific information related to your website visits.


Changes to this Privacy Policy

From time to time it may be necessary for Smiling Tuk Tuk to amend or make revisions to this Privacy Policy. If we make a change to the Policy, the revised version will be posted on our website. Please refer to this Privacy Policy for the latest information about our personal data practices.


Can I access my information and whom do I contact for more information?

You have the right to access, update, and correct inaccuracies in your personal data in our custody and control, subject to certain exceptions prescribed by law. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal da records.

Attn: Privacy Officer
Navatas Hospitality
203 Srihaburanukit Road, Minburi,
Bangkok Thailand 10510
E-Mail: info@navatas.com


As well as a right to access, update and correct information we hold about you, if you are resident in the UK, European Union or European Economic Area then you have the following additional rights:


  • To be told how long your personal data will be retained by us or the basis on which we make decisions about how long we retain your personal data.
  • To require that your personal data is deleted by us, subject to any necessary legal requirements we may have to retain the information
  • To object to our processing of your personal data or to restrict processing of your personal information (but we may be unable to provide certain services to you without processing this information)
  • To receive a copy of any personal data we hold about you in a portable format; To lodge a complaint with a relevant supervising authority (for example the Information Commissioner’s Office in the UK).
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