Structural Rehab Care platform by TRM Solution
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SRC Learning

Privacy Notice

Last updated: July 2026

This notice explains how we collect, use, and protect your data when you use SRC Learning health programs such as the Shoulder Survival Kit. Because these involve “health data” — a sensitive category — we handle it with extra care under Thailand's Personal Data Protection Act (PDPA).

In short

  • We collect only what is needed to care for your recovery
  • Your health data is used to tailor the program and keep you safe
  • We never sell your data or use it for advertising
  • You can view, correct, delete, or withdraw consent at any time

1. Who we are

TRM Solution Co., Ltd. is the data controller and operator of the SRC Learning system at srcth.com.

2. What we collect

When you enroll and use a program, we collect only what is needed to care for you:

  • Contact details: nickname, full name (only when requesting a certificate), phone number
  • LINE account (if you sign in with LINE): user ID and profile picture, to identify and contact you
  • Enrollment/usage data: sign-up and activation dates, program status and progress
  • Payment data: handled by an external payment provider — we do not store your card number

3. Health data (sensitive)

To tailor your program and keep you safe, we collect: your safety-screening answers, symptom checklist (location, duration, timing of pain, swelling, aggravating movements), self-exam results, the symptom group assigned by the system, the pain levels you report each time, end-of-stage assessment results, daily exercise logs, and whether you are an athlete.

4. Legal basis and consent for health data

General data is processed based on consent and to perform our service agreement. Health data is processed based on the “explicit consent” you give at enrollment (the acceptance you tick before starting), under Section 26 of the PDPA.

5. How we use your data

  • Tailor the program and exercises to your symptom group
  • Track your progress and safety during the program
  • Refer you to a physiotherapist or doctor when warning signs appear
  • Issue certificates when you request them
  • Follow up on your recovery and send your receipt

We do not sell your data to third parties, and we do not use your health data for advertising.

6. Who can access it

Only the SRC team and the physiotherapist/doctor caring for your program, and only as far as needed. Access is role-restricted and logged.

7. External providers

We use providers only as needed: cloud/infrastructure (secure storage), a payment provider (to process payments), and LINE (only if you sign in with LINE). All are bound to keep your data confidential.

8. Retention

Kept while you use the service and as long as necessary or required by law, then deleted or anonymized. You may request deletion.

9. Your rights

You may access and copy your data, correct, delete, restrict, object, port it, and withdraw consent at any time. Note: withdrawing consent for health data may mean we can no longer provide your program.

10. Not medical treatment

The content and programs are educational self-care material, not a personal diagnosis or prescription. If you have severe symptoms — intense pain, weakness, arm numbness, fever, or a recent injury/surgery — please see a doctor.

11. Data security

Stored on secure cloud infrastructure, encrypted in transit and at rest, role-restricted access, with periodic backups.

12. Minors and changes

This service is intended for adults; minors should use it under a guardian's consent. We may update this notice from time to time; the latest date is shown above.

To exercise your rights or ask about your personal data, contact trmsolution.service@gmail.com — TRM Solution Co., Ltd.