Privacy Policy

Introduction
At AST Development (Phuket) Co., Ltd, we understand the importance of personal data for our users and customers and commit to respecting and protecting your right to privacy and data protection.
This Privacy Policy describes the procedure for processing personal information provided or collected on our websites and applications (the «Platform»), where this Policy is published or referenced. The Policy complies with the data protection legislation applicable in the countries where we operate. In some cases, additional privacy notices applicable to specific regions may apply.
This document explains the purposes for which the Platform may process your personal data. By using the Platform or any services provided on its basis, you confirm that you have been informed about the procedure for using the collected personal data.
This Policy does not apply to other categories of data subjects not specified herein.
Corporate structure and data controller
AST Development (Phuket) Co., Ltd operates through the AST Development platform, as well as associated brands and projects. This Privacy Policy is issued on behalf of AST Development (Phuket) Co., Ltd. Accordingly, when this Policy refers to «AST Development», «we», «us», or «our», it means AST Development (Phuket) Co., Ltd as the company responsible for processing personal data.
The functions of the data controller are performed by AST Development (Phuket) Co., Ltd, unless otherwise specified in separate legal notices, service descriptions, or regional privacy notices applicable to a specific service or jurisdiction.
Information about the data controller, including legal and contact details, is available in the Legal Notice section on our website or on the relevant service pages.
A list of AST Development brands, projects, and services is available on the Platform.
For any questions related to this Privacy Policy or the processing of personal data, you can contact our Data Protection Officer (DPO) using the contacts provided on the Platform.
What personal data we collect
AST Development (Phuket) Co., Ltd may receive and process the following categories of personal data:
a) Personal data voluntarily provided by users:
First and last name;
Phone number;
Email address;
User preferences;
Types of notifications and alerts;
Favourite properties;
Location data — only if the user activates this function on their device;
Any other personal data voluntarily provided directly to AST Development.
b) Personal data voluntarily provided by agents, developers, or professionals:
Full name;
Residential address or registered legal address;
Phone number;
Email address;
Payment and settlement information;
Additional contact details (WhatsApp ID, Line ID, Skype ID, Messenger ID, WeChat ID, and/or website address);
Location data — only if this function is activated on the device;
Any other personal data voluntarily provided directly to AST Development.
c) Personal data voluntarily provided by property owners:
Name;
Phone number;
Email address;
Property data when publishing an ad, including:
Full or partial address;
Photos and/or videos;
Description and characteristics of the property;
Contact details (WhatsApp ID, Line ID, Skype ID, Messenger ID, WeChat ID) and/or website address.
d) Personal data collected automatically:
When using our websites and applications, AST Development may automatically collect technical and analytical data using cookies, server logs, and similar technologies. Such data includes:
Device data: operating system, device type and version, unique identifiers, mobile network information;
Location data — only with your explicit consent. Location can be determined by IP address, GPS, Wi-Fi access points, or mobile network base stations. These data are used exclusively for the operation of certain service functions, provision of services, and, if necessary, display of relevant advertising;
Navigation data: information about your activity on the Platform, including source websites, search queries made, date and time of visits, interaction with advertising, created notifications, and duration of visits. This data allows us to personalise content, offer relevant properties, and display personalised advertising.
Registration through social networks
You can create an account using a social network profile (e.g., Facebook or Google). This method of registration is completely voluntary. In this case, AST Development may gain access to certain personal data from your profile (such as name, ID, photo, gender, contacts, interests, and other information) — strictly within the privacy settings of the respective social network.
We only access the data you have permitted to share and use it exclusively for the same purposes as data obtained through direct registration. Before registration, you will be informed about the data being transferred. We recommend carefully reviewing the terms and privacy policy of the respective platform. Creating an account is impossible without the minimum necessary information.
Mandatory fields
Registration and use of AST Development services are voluntary. However, for categories (a), (b), and (c), some fields are mandatory for providing services. Such fields are usually marked with an asterisk (*) or accompanied by a corresponding notification. If you do not provide mandatory information, we will not be able to provide the requested services.
Purposes of processing personal data
Your personal data is processed for the purposes specified in this Privacy Policy, in accordance with applicable law, and taking into account the settings, choices, and control mechanisms available to you.
AST Development (Phuket) Co., Ltd may use personal data obtained directly from you or from devices associated with you for the following purposes:
Registering you as a user, creating and managing your account;
Providing services in accordance with the Legal Notice and applicable Terms of Use, including conditions that may be established in the future;
Responding to inquiries, consultations, and requests from users, agents, developers, and owners;
Posting, managing, and publishing ads provided by agents or property owners on our websites and applications;
Informing you about our services, activities, projects, updates, and new features of websites or applications via email and/or other electronic means of communication;
Personalising content and user experience, including the creation of user profiles to offer personalised ads, goods, or services from AST Development and/or our partners;
Ensuring the functioning, analysis, support, development, improvement, and optimisation of our websites, products, services, and internal processes;
Detecting, investigating, and preventing actions that violate our rules, Terms of Use, or applicable law;
Managing your participation in contests, promotions, or prize draws (if any);
Publishing user-generated content (e.g., comments or reviews), if this is provided for by the functionality of the Platform and with your consent.
Legal bases for processing personal data
AST Development (Phuket) Co., Ltd processes your personal data on one or more of the following legal grounds:
Execution of a contract: when processing is necessary to manage user accounts and provide services in accordance with the applicable Terms of Use;
Compliance with legal requirements: when processing is necessary to fulfil legal obligations imposed on the company by applicable law;
Legitimate interests: when processing is necessary to inform you about products, services, updates, and other communications from AST Development, provided that such interests do not violate your fundamental rights and freedoms;
Your consent: in cases where you have given explicit consent to:
receive information about AST Development products and services;
receive messages of interest using the contact details you provided;
process and store information contained in forms you have filled out.
You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the legality of personal data processing carried out before its withdrawal.
Transfer of personal data
AST Development (Phuket) Co., Ltd transfers your personal data to third parties only in the following cases:
To property owners, advertisers, developers, or agents, if such transfer is necessary to provide services or facilitate communication regarding ads and requests;
To portals, websites, or platforms where ads are posted or distributed;
When you request a service and/or additional information through feedback forms or other means of communication available on the Platform;
If you post an ad on the Platform, your contact details (provided by you) and the information about the property or product included in the ad become publicly available to Platform users and visitors.
Except for the above cases, your personal data are not transferred, sold, or disclosed to third parties. However, personal data may be transferred to state authorities, regulatory bodies, courts, or other third parties if this is required or permitted by applicable law.
Additionally, in cases provided for by law and upon your request to exercise the right to data portability, we will transfer your personal data to the recipient you specify in accordance with the law.

Access to Third-Party Personal Data
Depending on the purposes of processing, access to personal data may be granted to:
Third-party service providers acting on behalf of AST Development and processing personal data exclusively in accordance with our instructions and subject to necessary technical and organizational security measures. Such providers may include, in particular, hosting providers, electronic communication services, analytical services, as well as companies providing technical support and development services
Affiliated companies or TOPS.me projects, if such access is necessary for internal administrative, managerial, or operational purposes and is based on legitimate interest, in compliance with applicable data protection legislation
Google Personal Data Usage
Google may process certain personal data using cookies or similar technologies, provided you have consented through our websites or applications.
For more information about how Google uses data on partner sites, please visit:
Your Data Protection Rights
In accordance with applicable data protection legislation, you have the right to exercise the following rights:
Right of Access: to request information about whether AST Development processes your personal data and to access such data
Right to Erasure: to request deletion of your personal data
Right to Rectification: to request correction of inaccurate or incomplete personal data
Right to Withdraw Consent: if processing is based on consent. Withdrawal of consent does not affect the legality of processing carried out before withdrawal
Right to File a Complaint: with the authorized personal data protection authority in your country/region
Right to Data Portability: in applicable cases, to request transfer of your personal data to another data controller of your choice
Right to Restrict Processing: to request limitation of personal data processing in cases provided by law
Right to Object: to processing of your personal data, where permitted by law
Right Not to Be Subject to Automated Decisions: including profiling, if such decisions have legal effects or otherwise significantly affect your rights
Consequences of Exercising the Right to Erasure
If you exercise your right to erasure, all personal data associated with your account, as well as any information and/or content posted in your profile, will be deleted.
If the deletion request concerns personal data necessary for providing Platform services, AST Development (Phuket) Co., Ltd will be forced to terminate the contractual relationship with the user. As a result, the account will be deactivated, and the user will lose the ability to use services and make any related claims.
Deletion of personal data is carried out without prejudice to data retention or blocking obligations established by applicable data protection legislation.
Procedure for Exercising Rights
To exercise your rights, you may submit a written request to the website owner specified in the Legal Notice section or use the contact details provided at the bottom of each TOPS.me website or application.
Important Notice
Please note that some of the above rights may not be applicable to you depending on the data protection legislation in your country or region. If you submit a request to exercise a non-applicable right, we will not be able to fulfill such request. We recommend reviewing the list of applicable rights in advance to avoid misunderstandings.
Personal Data Security
AST Development (Phuket) Co., Ltd implements necessary technical and organizational security measures to protect your personal data from accidental loss, unauthorized access, unlawful use, alteration, or disclosure.
Access to personal data is granted exclusively to employees, contractors, and third parties who require such data for legitimate business purposes. In all such cases, personal data processing is strictly in accordance with our instructions and subject to confidentiality obligations.
For additional protection, we have implemented procedures for identifying, assessing, and responding to potential security incidents and personal data breaches. In cases provided by applicable law, we will notify users and relevant data protection authorities of security breaches within legally prescribed timeframes.
It is important to understand that despite implementing all reasonable security measures, data transmission over the Internet and electronic storage cannot be absolutely secure, and 100% security cannot be guaranteed.

Personal Data Retention Period
AST Development (Phuket) Co., Ltd processes and stores your personal data only for the period necessary to achieve the purposes specified in this Privacy Policy and in compliance with applicable legislation requirements.
The criteria for determining personal data retention periods include:

Processing Purpose: personal data is stored as long as necessary to achieve the collection objectives. Typically, this means data is retained during the period of your account activity and until its deletion upon your request
Data Collection Basis: for example, if processing is based on consent, you have the right to revoke such consent at any time
Contractual and Legal Obligations: mandatory retention periods established by contractual, accounting, tax, and other regulatory requirements

Please note that in certain cases, AST Development (Phuket) Co., Ltd is obliged to store specific categories of personal data for an additional period of time even after account deletion or service termination — in accordance with data protection legislation, tax, or other applicable regulations.
Confidentiality
All employees, contractors, partners, and other specialists collaborating with AST Development (Phuket) Co., Ltd and involved in providing services to users are obliged to maintain strict confidentiality and not disclose or misuse information to which they may gain access for unlawful purposes.
Any information provided by the user is considered confidential and is used exclusively for the purposes of managing the user’s account and/or providing services ordered through TOPS.me (if applicable).
AST Development (Phuket) Co., Ltd undertakes not to disclose user information to third parties except when such disclosure is required by applicable law, government authorities, or court decisions.
International Transfer of Personal Data
AST Development (Phuket) Co., Ltd operates on an international level, which may necessitate transferring your personal data to third countries for operational, technical, or service purposes in certain cases.
Personal data transfer may be carried out to:

Affiliated companies, projects, or AST Development partners listed in the Legal Notice section
Third-party service providers whose participation is necessary for Platform operation and service provision

In all cases, only the minimally necessary amount of personal data is transferred strictly within the purposes specified in this Privacy Policy.
Data Transfer Outside the European Economic Area (EEA)
If you are an EEA resident and your personal data is transferred outside the EEA, AST Development (Phuket) Co., Ltd ensures compliance with applicable data protection legislation requirements.
Such transfer is carried out with one or more of the following protective mechanisms:

Transfer to countries recognized by the European Commission as having an adequate level of personal data protection
Application of appropriate safeguards, including:
Standard Contractual Clauses (SCC)
Binding Corporate Rules (BCR)
Approved codes of conduct or certification mechanisms
Other legally provided mechanisms ensuring an appropriate level of data protection

You have the right to request additional information about the applied international data transfer mechanisms, including copies of relevant contractual provisions, by contacting our Data Protection Officer (DPO) using the contacts provided on the Platform.
Special Categories of Personal Data
AST Development (Phuket) Co., Ltd does not intentionally collect or process personal data relating to particularly sensitive or special categories of personal data, except when such data is directly and voluntarily provided by the user.
Special categories of personal data include, but are not limited to: racial or ethnic origin, political opinions, religious, philosophical, or other beliefs, trade union membership, genetic data, biometric data used for unique personal identification, health data, and information about sexual life or sexual orientation.
If such data is voluntarily provided, its processing is carried out strictly in accordance with applicable data protection legislation requirements and exclusively for the purposes explicitly stated at the time of collection.
Minors
The Platform is not intended for or targeted at individuals under the age of sixteen (16). Use of the Platform by such individuals is permitted only with prior consent and under the supervision of their parents or legal representatives.
AST Development (Phuket) Co., Ltd does not intentionally collect or process personal data of individuals under the age of sixteen (16).
If parents or legal representatives believe that a minor has provided AST Development with personal data without their consent, they should immediately notify us using the contact details provided at the bottom of our websites. Upon receiving such notification, we will take appropriate measures in accordance with applicable data protection legislation.
Marketing Communications
AST Development (Phuket) Co., Ltd undertakes not to use your personal data for direct marketing purposes without your prior explicit consent.
At the same time, if we have a business relationship with you, we may send information about our products and services based on legitimate interest, in compliance with applicable data protection legislation requirements.
If at any time you wish to stop receiving promotional or marketing information from AST Development or third parties, you can opt out of such communications free of charge in the following ways:

By using the unsubscribe link contained in any marketing message
By changing notification settings in your account
By contacting us using the contact details provided on the Platform

Please note that even if you opt out of receiving marketing or advertising messages, AST Development (Phuket) Co., Ltd may continue to send you important non-commercial messages. Such messages include notifications related to service provision, technical issues, account inactivity, security, error detection and prevention, as well as compliance with Legal Notice requirements and Platform operational procedures.
Social Media
AST Development (Phuket) Co., Ltd informs you that when subscribing to our profiles or pages on social media platforms and interacting with them, we may process certain personal data in accordance with the privacy settings of the respective social media platform and its privacy policy. Such processing is carried out exclusively for the purpose of adding you to the list of subscribers and interacting with you through these platforms.
Depending on your privacy settings, the fact of subscription or interaction may be displayed in your profile or on your page, and your contacts may receive relevant notifications. By default, we only have access to publicly available data, such as username and profile picture. We do not have access to other personal data or social media activity unless you make them publicly available.
Through social media, we may inform you about our activities, events, news, products, and services of AST Development (Phuket) Co., Ltd and our partners. If you no longer wish to receive such information, you can unsubscribe at any time using the «unfollow» function of the respective social media platform.
We inform you that with your prior consent, your comments or other interactions on social media may be published outside the respective social media platform or using tools other than official APIs (e.g., Twitter/X API or Facebook API). The content of messages will not be altered, translated, or partially deleted, and your full username will be обязательно indicated. In case of deletion or modification of the original content on social media, we will make reasonable efforts to remove or adjust the published material within 24 hours from receiving the notification.
AST Development (Phuket) Co., Ltd may use third-party advertising and analytics services (such as Google Ads, Facebook Ads, and similar platforms) to display information or advertisements related to our products or services, conduct remarketing, and/or create similar audiences based on users interacting with us or requesting additional information through social media. These services process data in accordance with their privacy policies. You can manage the use of cookies and similar technologies through the settings of the respective platforms.
Please note that AST Development (Phuket) Co., Ltd does not have the ability to access, modify, or delete your personal data on social media platforms. Such actions can only be performed by the respective social media platform. For more information about how social media platforms process your personal data, we recommend reviewing their privacy policies:

Facebook:
X (Twitter):
Instagram:
YouTube:
LinkedIn:

Social Media Participation Rules
AST Development (Phuket) Co., Ltd provides users with the opportunity to freely comment and interact on its social media pages. However, to ensure proper functioning and maintain a respectful and comfortable atmosphere, the following rules must be observed.
We reserve the right to remove comments, images, and any other content if it:

Contains obscene language, insults, threats, incitement to hatred, or other offensive content
Engages in harassment or threats against individuals, brands, organizations, or social groups
Threatens fundamental rights and freedoms
Violates the right to honor, personal and family privacy, or the right to image
Contains personal data of third parties or objects protected by intellectual or industrial property rights
Contains viruses, malware, or other elements capable of disrupting the operation of AST Development systems or third-party systems
Is used for advertising or commercial purposes unrelated to AST Development activities, or is posted repeatedly (spam)
Is related to illegal activities

Users violating these rules may be blocked. AST Development (Phuket) Co., Ltd also reserves the right to notify competent authorities and provide data necessary to identify the author of unlawful content.
Please note that social media interaction is public (depending on your privacy settings) and may be accessible to third parties. AST Development (Phuket) Co., Ltd does not control the use of such information by other users and is not responsible for third-party actions (e.g., sending unsolicited messages).
Facebook Page (Fanpage)
AST Development (Phuket) Co., Ltd uses Facebook pages as a joint data controller with Facebook Ireland Limited (or its successors).
Under this joint responsibility, we only receive anonymized statistical data about visitor traffic and user activity. Information about how Facebook processes personal data is available in its Privacy Policy:

The main terms of the joint control agreement are located at:

We do not have access to personal data processed by Facebook through statistical services. The legal basis for processing anonymized data is our legitimate interest in analyzing page visitor interests.
Contests and Sweepstakes
Participation in contests, promotions, and sweepstakes conducted through our social media is governed by separate rules and conditions for each event.
Your provided personal data is used exclusively for managing your participation. Providing contact information is mandatory for participation, as specified in the contest rules or participation form.
Data sharing with third parties is possible only in the following cases:

As required by law
In case of winning — publication of the winner’s name with their consent or based on AST Development’s legitimate interest in ensuring contest transparency
If the organizer or prize provider is a third party and prize delivery requires data sharing (you will be notified in advance)

Personal data is stored during the contest or sweepstake period and subsequently within the terms established by law. In some countries, such data may be stored up to four (4) years, for example, for tax purposes.
Automated Decisions and Profiling
AST Development (Phuket) Co., Ltd integrates content from various classified ad websites and partner platforms into its Platform and directs relevant and quality traffic to these ads. Additionally, we can generate additional traffic by showing suitable ads to the right user at the right time using native advertising and recommendation products.
To provide services in accordance with the Legal Notice and ensure a relevant and quality user experience, we use automated decision-making procedures based on your actions and choices in the Platform search system. These processes help generate search results, recommendations, and advertising offers that match your queries and interests.
User Profiling
We also create user profiles to enhance the relevance of displayed content and advertising. This is achieved using cookies (with your consent) and similar technologies that collect information including:

Search queries you have performed
Ads or sections you have interacted with
Ads you have previously viewed
Ads displayed to you on our websites or in applications

This information enables us to:

Suggest properties, services, or ads similar to those you have previously searched for or viewed
Display personalized ads related to your interests

In cases permitted by applicable law, we may also store pseudonymized IP addresses to deliver commercial messages or content tailored to your general location.
Automated decision-making and profiling by AST Development do not result in legal consequences or other significant effects for the user. You have the right to object to such personal data processing in accordance with applicable law.
Links to Third-Party Resources
The Platform may contain links to third-party websites, applications, or platforms that AST Development (Phuket) Co., Ltd considers potentially useful or informative for users.
Please note that AST Development does not control, endorse, or recommend the content, services, privacy policies, or terms of use of such third-party resources, and is not responsible for the manner in which personal data is processed on them.
We strongly recommend that you review the privacy policies and terms of use of any third-party websites or platforms you visit.
This Privacy Policy applies exclusively to personal data collected and/or processed by AST Development (Phuket) Co., Ltd within the Platform’s operation.
Changes to the Privacy Policy
AST Development (Phuket) Co., Ltd uses your personal data solely in accordance with the version of the Privacy Policy that was in effect at the time of data collection.
We reserve the right to make changes or additions to this Privacy Policy at any time by publishing an updated version on the Platform. Therefore, we recommend checking the Privacy Policy each time you visit the Platform. The date of the last update indicated in the document will inform you of any changes. Continued use of the Platform after changes are made constitutes your acceptance of the revised Policy.
If we decide to use personal data for purposes other than those stated at the time of collection, we will notify you via email (if we have your email address). If such new purposes require your consent, you will be given the opportunity to provide or withhold such consent.
If any provision of this Privacy Policy is found to be invalid or unenforceable, it will not affect the validity and enforceability of the remaining provisions, which will remain in full force and effect in accordance with applicable law.
Date of Last Update:
December 25, 2025