Privacy Policy
Effective 3 September 2026 · updated 22 September 2026. Version 2. · Русский
1. Who we are
The data controller is Tropicana Development Group Real Estate & Construction Co., Ltd., registration number 0835566012071, address: 7/84 Moo 8, Thep Krasattri, Thalang, Phuket 83110, Thailand ("we", "Tropicana Development").
Data enquiries: privacy@tropicanaos.com.
2. Scope
The website cobroking.pro, the coBroking phone app and the Telegram bot @cobroking_bot (together, the "Service").
3. What we collect
When you open the site: technical request data (IP address, browser type, page) processed by our host Cloudflare for security and kept for no more than 7 days. The site carries no advertising or analytics trackers.
When you choose a language or currency, or browse projects: the site keeps your choice and the list of viewed projects only in your browser (localStorage). This data is not sent to us.
When you enter the Telegram bot: your first and last name from your Telegram profile, your Telegram ID and username, chosen language, the project you came from, time of entry, and the campaign tag if you arrived from an advertisement.
When you sign in by email, with Google or with Facebook: your email address and the name on your profile. We hold no password — email sends a one-time link, and Google and Facebook confirm the address is yours. From Google and Facebook we ask only for the address and the name: we neither receive nor request your friends, posts or feed.
When you or an agent leave a contact: name, phone number, Telegram username, project and unit of interest, conversation status and agent notes.
When you request a unit hold: project, unit number, time of request, agent. The request goes to the developer's sales office: name, phone with the last digits hidden, project and unit. The developer's answer — confirmation, refusal, deposit invoice — is kept in the hold history.
When an agent prepares a booking: documents you handed to the agent for the contract (for example a passport page) — the agent uploads them, they sit in closed storage and are visible only to the agent and their manager. The developer receives the prepared contract and the invoice, not the documents themselves.
When a message arrives in a work group on WhatsApp or Telegram where Tropicana Development is a member: text, author and attachments are kept as working correspondence with developers and partners. Personal chats and groups outside Tropicana's work are not stored.
4. Why
To show you suitable property and connect you with an agent who speaks your language. Basis: performance of a contract at your request (PDPA s. 24(3)).
To keep the history of the conversation so we do not ask twice. Basis: legitimate interest (PDPA s. 24(5)).
To send you selections, price changes and project news. Basis: your separate consent (PDPA s. 19), which you can withdraw at any time with /stop in the bot.
To understand which advertising brings clients: the campaign tag is tied to your enquiry, not to a cookie. Basis: legitimate interest.
To protect the Service from abuse. Basis: legitimate interest.
5. Who we share with
Tropicana Development agents and managers handling your enquiry. Other agents see your number only partially.
The developer's sales office, only when you ask to be registered, to reserve or to view a unit: name, phone with the last digits hidden, and at booking — the prepared contract and the deposit invoice. The invoice is issued by the developer; money goes to the developer directly and never passes through us.
Cloudflare, Inc. (USA, data centres worldwide) for hosting and database storage. Telegram for message delivery. Both operate under their own privacy policies and data processing agreements.
We do not sell data and do not pass it to advertising networks.
6. International transfer
Data is stored on Cloudflare infrastructure outside Thailand: the database in the Asia-Pacific region, contract documents in storage of the same region, work-group attachments in storage in North America. Cloudflare provides the level of protection required by PDPA s. 28 under standard contractual terms.
7. Retention
Bot entry without a subsequent contact: 12 months. An enquiry with a contact: for the duration of the conversation and 24 months after the last action. A hold: 48 hours active (30 days once the deposit is paid) and a record in history. Contract documents: while the deal is in progress and 12 months after completion or refusal, then deleted. Working correspondence with developers: 24 months.
We delete earlier on your request unless the law requires the record to be kept.
8. Your rights
To obtain a copy of your data, correct it, delete it, restrict processing, object, withdraw consent, receive data in a machine-readable form.
Write to privacy@tropicanaos.com or send /delete_me to the bot; your data will be deleted within 30 days. You may lodge a complaint with the Personal Data Protection Committee of Thailand (PDPC).
9. Children
The Service is not intended for persons under 20.
10. Security
Database access is limited to staff with a role in the system, data travels over TLS, every action on an enquiry is logged.
In case of a breach affecting your rights we notify the PDPC within 72 hours and you without undue delay.
11. Cookies
The site sets one functional access cookie after you sign up in the bot: it remembers that you are signed in, lives up to a year and is renewed on visits. There are no analytics or advertising cookies; language and currency choices stay on your device.
To remove it, open cobroking.pro/logout or clear the site data in your browser.
12. The phone app
The app shows the same catalogue and keeps pages, availability and prices inside the package so they open without a connection. It has no separate account: sign-in is the same as on the site.
Camera and microphone. The app asks for them only when you tap "Go live" on the showing screen: picture and sound reach the other party in real time and are not recorded, by us or on the device. They are used nowhere else.
Contacts. The app asks for the phone book only when you tap the WhatsApp or Telegram call button: it looks up the call row on that contact and opens the messenger. The phone book is not read in full, is not sent to us and does not leave the device.
Photos. The app does not open your gallery on its own. Contract documents are chosen and uploaded by the agent from their own device, as described in section 3.
The app collects no device identifiers, does not determine your location and contains no advertising or analytics trackers.
13. Changes
A new version is published on this page with its date. Material changes are announced in the bot.