Privacy Notice — PackMobi
Last updated: 26 October 2026 · Version 1.1
This is a translation of the Thai original (
PrivacyPolicy.md). Where the two differ, the Thai version prevails, except where mandatory consumer or data-protection law in your country provides otherwise.
This notice explains how the Developer (the maker and operator of the PackMobi application — in this notice, "the Developer" or "we") collects, uses and discloses your personal data and that of other people involved when you use PackMobi.
It is written under Thailand's Personal Data Protection Act B.E. 2562 (PDPA) and is also aligned with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the UK GDPR. Where the two regimes differ, we apply the stricter standard.
PackMobi is built for business users aged 18 or over. It is not directed at children, and we do not knowingly collect children's data.
1. The Developer, contact details and service scope
| Service provider | The Developer of the PackMobi application |
| Data protection email | privacy@packmobi.com |
| Data Protection Officer (DPO) | Not appointed. The nature and scale of our processing does not meet the thresholds in PDPA section 41 or GDPR Article 37. Every request may be sent directly to the email above. |
| Service scope | PackMobi is currently offered to merchants in Thailand. If we later offer it to people in the European Economic Area (EEA) or the United Kingdom, we will appoint a representative under GDPR Article 27 and publish the details in this section. |
2. Who controls what
Three parties are involved, and their legal roles are not the same:
| Data | Controller | Processor |
|---|---|---|
| Videos, audio and the data burned into the video | The merchant using the app, because the merchant decides to record and uses the result | None in the current version: clips never leave the device, so the Developer neither receives nor can access your clips. When cloud service is enabled in future, the Developer will act as processor on the merchant's instructions under clause 3 of the Terms of Use. |
| Technical data created by the time-anchor request (IP address, User-Agent) | The Developer | Cloudflare (see section 5) |
| Account, payment and link-view records (when they exist) | The Developer | See section 5 |
3. The personal data involved
PackMobi is local-first: almost all data is recorded and processed on your own device.
a. Video, audio and the data burned into the clip Video of the packing process, which may show the faces and bodies of staff, customers or other people near the packing table; audio (recorded only when you turn the microphone on, which is off by default); and data burned permanently into the image: tracking number, packing-table name, the packer's name or code (only where the merchant has entered one — the field may be left blank, and blank is the default), order number, evidence id, and the date and time.
Burned-in data cannot be removed. It is written into the image itself and sealed with a hash so that any later alteration can be detected. The only way to remove or change it is to delete the whole clip. To keep personal data to a minimum, we recommend that merchants enter an employee code or initials rather than a full name in the "packer name" field.
b. Data you enter into the app Packing-table name, packer name or code, tracking number, order number and settings — stored in the app's database on your device.
c. Technical data IP address and User-Agent, created when the app requests the time from our server to anchor its trusted clock. We treat an IP address as personal data in line with GDPR practice, and state it here rather than leave it out.
What the app does not do
- It does not request access to your location, contacts, phone number, messages or any other files on your device.
- It contains no advertising, tracking or usage-analytics SDK of any kind.
- It uses no facial recognition and no biometric processing on your clips. Barcode scanning runs on the device with a model bundled in the app and sends no image off the device. We therefore process no special category data under GDPR Article 9 or sensitive data under PDPA section 26.
- There is no automated decision-making or profiling that produces legal effects for any person (GDPR Article 22).
4. Purposes and legal bases
| Purpose | Data used | Legal basis |
|---|---|---|
| Running the app as you request and anchoring its clock | Technical data (3c) | Performance of a contract — PDPA s.24(3) · GDPR Art. 6(1)(b) |
| Recording packing evidence to prevent and defend claims of missing, damaged or lost goods | Video, audio and burned-in data (3a) | Legitimate interests of the merchant — PDPA s.24(5) · GDPR Art. 6(1)(f) |
| Keeping the service secure and preventing abuse | Technical data | Legitimate interests — GDPR Art. 6(1)(f) |
| Meeting legal obligations such as accounting, tax and lawful orders | Account and payment data (when applicable) | Legal obligation — PDPA s.24(6) · GDPR Art. 6(1)(c) |
Legitimate Interests Assessment. The recording exists to prove what was placed in the box at that moment, which no other evidence replaces. It is limited to the packing table and to the duration of packing; it is not continuous monitoring of any person. The footage is not used to assess staff performance, for marketing, or to train artificial-intelligence models. The impact on people appearing in the footage is therefore limited, and it is balanced by notices at the packing point, a limited retention period, and the right to object described in section 9.
We do not rely on consent as the main basis for recording. In a real workplace, consent cannot genuinely be obtained from everyone who may appear in frame, and consent that can be withdrawn retrospectively is incompatible with evidence that has already been sealed. A basis that cannot be honoured in practice would make this notice meaningless.
5. Disclosure and sub-processors
In the current version (v1) your clips are stored only inside the app's private storage on your device. They are not sent to the Developer's servers or to any provider's servers. Sharing a clip to another app such as LINE or Messenger is an action you take through your device's share sheet; from that point the file is governed by the receiving app's policy, which is outside our control.
| Provider | Role | Data involved | Status |
|---|---|---|---|
| Cloudflare, Inc. | Serves the time request and protects against attack | IP address, User-Agent | In use in v1 |
| Google LLC (Google Play) | Distributes the app and collects fees | Purchase data that Google holds under its own policy | When paid plans exist |
| Supabase, Inc. and Cloudflare R2 | Database and file storage for the cloud service | Clips, evidence data, account data, link-view records | Not yet enabled. This notice will be updated before it is. |
We do not sell, trade or pass on your personal data for advertising.
6. International transfers
The server that answers the time request is part of Cloudflare's global network, so your request may be answered from a data centre outside Thailand, and the future cloud service will store data outside Thailand.
- For data under the PDPA, transfers follow sections 28–29, relying on appropriate safeguards in our contracts with providers.
- For data under the GDPR, transfers outside the EEA rely on Standard Contractual Clauses (SCCs) in each provider's data processing agreement, together with a Transfer Impact Assessment. Copies of these safeguards are available on request at the email in section 1.
7. Retention
| Data | Period |
|---|---|
| Clips and evidence data on the device (v1) | Kept on your device until you delete them, clear the app's data, or uninstall the app. As controller, the merchant is responsible for setting and applying its own retention period. We recommend deleting clips once the carrier's claim window has passed. |
| Clips in the cloud service (future) | 90 days from the date the system receives the clip |
| Technical data (IP, User-Agent) | The Developer keeps no logs of time requests. Cloudflare keeps short-term logs for security and attack prevention, for the period applicable to that service. |
| Account and accounting records (future) | As required by accounting and tax law |
Exception. Where a clip or record relates to a dispute, a legal claim, or an order from a competent authority, retention is extended until that matter is finally resolved (PDPA s.33 · GDPR Art. 17(3)(e)).
8. Security measures
- Clips and the evidence database are held in the app's private storage, which Android prevents other apps from reading, and are covered by Android's default full-device encryption.
- The system's automatic backup is switched off (
allowBackup=false), so your clips are not copied to Google's backup service. - Connections to our server use HTTPS only.
- Each clip carries a hash, so later alteration of the file can be detected.
- The key used to sign evidence is held separately from the database, so someone who reaches the data still cannot forge a signature.
9. Your rights
You, and people appearing in the clips, have the following rights (PDPA ss.30–36 · GDPR Arts. 15–22):
| Right | What it means |
|---|---|
| Access and copy | Ask what data exists and obtain a copy |
| Rectification | Correct data that is inaccurate or out of date |
| Erasure | Have data deleted when there is no longer a reason to keep it |
| Restriction | Have use of the data paused |
| Objection | Object at any time to processing based on legitimate interests. We will stop, unless there are compelling legal grounds that override, such as an unresolved legal claim. |
| Data portability | Receive the data in a machine-readable format |
| Withdraw consent | Where any processing relies on consent |
| Complain | Lodge a complaint directly with a supervisory authority (section 14) |
Response time. We answer within 30 days of receiving a request and verifying identity. Where a request is complex or numerous, we may extend by up to two further months and will explain why within the original period (GDPR Art. 12(3)). Exercising your rights is free of charge.
If you appear in a clip (for example as an employee or a customer): the merchant who made the recording is the controller, and in the current version the Developer holds no copy of that merchant's clips at all, so please contact the merchant first. If you cannot reach them or receive no answer, write to the email in section 1 and we will help and give technical support as far as we are able.
Limits we state plainly. An erasure request may be refused or deferred where the clip is evidence in an unresolved dispute or must be kept by law. Data burned into the image cannot be erased in part — only the whole clip can be deleted. We write this down because a promise that cannot be kept is worse than no promise.
10. Consequences of not providing data
The app needs camera access to record evidence. Without camera permission, the evidence-recording feature cannot be used. Audio recording is off by default, so the app does not ask for microphone permission at all and records evidence normally without sound. If you switch audio recording on and then refuse microphone permission, the app will ask for it again — or you can switch audio off in settings and carry on recording without sound.
11. Personal data breach notification
If a personal data breach occurs in a system we operate, we will notify the supervisory authority within 72 hours of becoming aware of it under GDPR Article 33, and within the period required by PDPA section 37(4). Where the breach presents a high risk to people's rights and freedoms, we will also notify the affected individuals. Acting as a processor for a merchant, we will notify that merchant without undue delay (GDPR Art. 33(2)).
12. No cookies and no tracking in the app
The app uses no cookies, embeds no tracking pixels and collects no usage statistics. Related web pages, such as the evidence verification page, use only cookies strictly necessary for them to work and will carry their own notice if that changes.
13. Records of processing
We maintain and update records of our personal data processing activities under PDPA section 39 and GDPR Article 30.
14. How to complain
- Thailand: the Office of the Personal Data Protection Committee (PDPC)
- EEA: the data protection authority of the country where you live, work, or where the matter arose (GDPR Art. 77)
- United Kingdom: the Information Commissioner's Office (ICO)
We ask you to contact us at the email in section 1 first so that we can put things right quickly, but contacting us is not a condition of complaining.
15. Changes to this notice
We will update this notice when our processing changes — in particular before the cloud service is switched on — and will announce material changes through the app or the contact details you have given us before they take effect.
Revision history
- Version 1.0 (26 October 2026): first version.