Top Tier Media is a marketing agency. We connect to our clients' advertising accounts (Google Ads, Meta Ads, etc.) through official APIs to manage and report on their campaigns. We use this data only to provide our services. We never sell or share client advertising data with third parties.
1. Introduction
This Privacy Policy describes how Top Tier Group Company Limited, operating under the brand name "Top Tier Media" ("we", "us", "our", or "the Agency"), collects, uses, stores, and protects information when we provide digital advertising services to our clients.
We are a marketing agency based in Bangkok, Thailand. This policy applies to:
- Visitors to our website
- Clients who engage us to manage their advertising campaigns
- Data we access through advertising platform APIs (including the Google Ads API and Meta Marketing API) on behalf of our clients
2. Information We Collect
2.1 Information You Provide Directly
When you contact us or engage our services, we may collect:
- Name, email address, phone number, and company name
- Business information relevant to your advertising campaigns
- Billing and payment information (processed by third-party payment providers)
2.2 Information We Access Through APIs on Behalf of Clients
When you become our client and authorize us to manage your advertising accounts, we access data through the official APIs of advertising platforms, including but not limited to:
- Google Ads API — campaign data, ad performance, keywords, bidding, conversion tracking, account structure
- Meta Marketing API — Facebook and Instagram campaign data, ad creative, audience targeting, performance metrics
- TikTok Marketing API — TikTok campaign data and performance
- LINE Ads Platform — LINE advertising data
- Other platform APIs as needed to deliver agreed services
We only access the data necessary to manage and report on your campaigns. We do not access personally identifiable information of the end-users (consumers) who interact with your ads, beyond what is already provided in aggregate form by the advertising platforms.
2.3 Website Analytics
Our website may use standard analytics tools (such as Google Analytics) to understand how visitors use our site. This data is aggregated and does not personally identify individuals.
3. How We Use Information
We use the information we collect and access strictly for the following purposes:
- Service delivery — to create, manage, optimize, and report on advertising campaigns on behalf of our clients
- Performance reporting — to generate periodic reports about campaign performance for the specific client who owns the data
- Strategic recommendations — to provide our clients with insights and recommendations to improve their advertising effectiveness
- Communication — to respond to inquiries, send service updates, and conduct ordinary business communication
- Billing and accounting — to process payments and maintain financial records as required by Thai law
- Compliance — to comply with our obligations under applicable law and the terms of service of advertising platforms
4. Google Ads API Data Usage — Specific Disclosure
In accordance with Google's API requirements, we provide the following specific disclosure regarding data we access through the Google Ads API:
- We access Google Ads data only for accounts where the account holder (our client) has explicitly granted us authorization
- We use Google Ads data only to manage and optimize the client's own advertising campaigns and to provide reporting to that specific client
- We do not sell, license, lease, or otherwise monetize Google Ads data accessed through the API
- We do not share Google Ads data with third parties except as required to deliver our services (for example, secure cloud storage providers) or as required by law
- We do not use Google Ads data to train machine learning or generative AI models that are sold or licensed to third parties
- Clients may revoke our API access at any time through their Google Ads account settings, and we will stop accessing their data immediately upon revocation
5. Meta Marketing API Data Usage
The same principles described in Section 4 apply to data we access through the Meta Marketing API (Facebook, Instagram, Messenger, Audience Network). We access this data only with client authorization and only to provide agreed services.
6. Data Storage and Security
We take reasonable technical and organizational measures to protect the information we collect and access, including:
- Storing data in access-controlled systems
- Using encrypted connections (HTTPS/TLS) for data in transit
- Limiting employee access to data on a need-to-know basis
- Reviewing our security practices on a regular basis
No method of data transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect data, we cannot guarantee absolute security.
7. Data Retention
We retain client account data and campaign data for as long as the client engagement is active, and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:
- Active client data is retained for the duration of the service agreement
- After service termination, campaign and reporting data may be retained for up to 2 years for accounting, audit, and legal compliance purposes
- Personal contact information may be retained as required under Thai accounting and tax law (typically 5–10 years)
- You may request earlier deletion of personal data by contacting us, subject to legal retention requirements
8. Data Sharing
We do not sell client data. We may share information only in the following limited circumstances:
- Service providers — trusted infrastructure providers (cloud hosting, email, accounting tools) bound by confidentiality obligations and acting on our behalf
- Legal requirements — if required by law, court order, or regulatory authority in Thailand or another applicable jurisdiction
- Business transfers — in the event of a merger, acquisition, or sale of business assets, with notice to affected clients
- With your consent — when you explicitly authorize us to share specific information with a specific third party
9. Your Rights
Under the Thailand Personal Data Protection Act (PDPA) and other applicable data protection laws, you have the following rights regarding your personal data:
- Right to access — request a copy of the personal data we hold about you
- Right to correct — request correction of inaccurate personal data
- Right to delete — request deletion of your personal data, subject to legal retention requirements
- Right to restrict processing — request that we limit how we process your data
- Right to withdraw consent — withdraw consent for processing where consent is the legal basis
- Right to revoke API authorization — clients may revoke our access to their advertising accounts at any time directly through the platform (Google, Meta, etc.)
- Right to lodge a complaint — file a complaint with the Personal Data Protection Committee of Thailand if you believe your rights have been violated
To exercise any of these rights, contact us at tk.kananithikul@gmail.com.
10. Cookies
Our website may use cookies and similar technologies for basic functionality and analytics. You can control cookies through your browser settings. Disabling cookies may affect some functionality of our website.
11. Children's Privacy
Our services are intended for businesses and individuals aged 18 and over. We do not knowingly collect personal information from children under 18.
12. International Data Transfers
Advertising platform APIs (Google, Meta, etc.) and cloud service providers may process data outside of Thailand. By engaging our services, you acknowledge that data may be transferred to and processed in jurisdictions with different data protection laws. We require our service providers to maintain appropriate safeguards for international transfers.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. The "Last updated" date at the top of this page will reflect the most recent revision. Material changes will be communicated to active clients through reasonable means (such as email).
14. Contact Us
If you have questions, concerns, or requests related to this Privacy Policy or our data practices, contact us at:
- Email: tk.kananithikul@gmail.com
- Company: Top Tier Group Company Limited
- Location: Bangkok, Thailand