Privacy Policy for Smilie Pte. Ltd.
Privacy is Smilie’s code: No matter where you are in the world, where you reside, where your citizenship lies, or where your data comes from, we offer the same high standards of privacy protection to all our customers. We hope our Privacy Policy will provide clear, detailed, and easy-to-read information about Smilie’s privacy practices and how we process personal data.
When we refer to Smilie, we mean the Smilie entity with which you have contracted. If there are any capitalized terms in this Privacy Notice that are not defined, then those terms will have the meaning defined in your agreement with us.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.
This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Smilie. This policy is not applicable to any information collected offline or via channels other than this website.
Contents of this Notice
How Smilie processes your personal data
Smilie collects personal data such as Customer Account Data directly from you — as a customer or a visitor — when you visit Smilie’s website, request a product, service or access to an event, or when you contact a member of the Smilie team or sign up for a Smilie account to use our products and services. Smilie also indirectly collects the personal data of your end users called Customer Usage Data (e.g., communications metadata) and Customer Content (e.g., communications content).
Data about our customers
We process customer contact details such as your name, email, and phone number directly from you when you make a request, contact a member of our team, or sign-up for a Smilie account. Read this section to learn more about the types of data we collect about you, why we collect it, and how we store it.
Data about our customers’ end users
We process your end users’ communications-related data such as phone numbers, email addresses, physical addresses, friendly names that you and/or your end users create. We also process the content of communications sent by you or your end users to provide services to you and to carry out necessary functions of our business as a service provider.
How Smilie shares personal data
First things first: we do not sell your personal data, or the personal data of your end users. We also do not allow any personal data to be used by third parties for their own marketing purposes (except in cases where you explicitly request or provide consent for us to do so, such as at a conference when you direct us to share your information with a sponsor).
However, we do need to share it in some circumstances. These may be to provide you services (e.g., to arrange delivery with a third party provider), or when necessary for our suppliers to provide services to us, or for another reason listed here.
Cookies and tracking technology
Smilie uses common information-gathering tools such as cookies, web beacons, pixels and other similar tracking technologies to automatically collect information as you navigate our websites, our services or when you interact with emails we sent to you. You can manage these technologies easily on our websites.
Security information
While there is no such thing as perfect security, we are committed to maintaining reasonable and appropriate security measures to ensure that your personal data is protected both online and offline. Read this section to learn more about our security measures and how you can better protect your account.
How Smilie Processes Your Personal Data
When we talk about “personal data,” we’re talking about a broad range of information. Data protection laws around the world define this concept in different ways, but in general, we mean any information that relates to an identifiable, living individual person. In other words, a person’s phone number is personal data, while a business’s phone number is not.
In addition, some data protection laws and privacy laws in certain jurisdictions differentiate between “controllers” and “processors” of personal data. A controller decides why and how to process personal data. A processor does not make decisions about personal data; it only processes personal data on behalf of a controller based on the controller’s instructions.
With this background, let’s take a high level look at the personal data Smilie collects and how we process it.
If you are a customer of ours, Smilie processes personal data in different ways when you use our products and services.
We process your personal data as a customer (or potential customer) of Smilie’s services — information that we refer to as Customer Account Data (e.g., your contact information) — when you visit a Smilie public-facing website like Smilie.com; sign up for a Smilie event; reach out to our Sales team; or sign up for a Smilie account.
We process the personal data of your end users who use or interact with your application that you’ve built on Smilie’s platform, like the people you communicate with by way of that application. This includes information we use to route messages and metadata about messages — we refer to this information as Customer Usage Data — and it also includes the contents of communications, which we refer to as your Customer Content.
Smilie processes these categories of personal data differently because the direct relationship we have with you, our customer, is different from the indirect relationship we have with your end users.
When Smilie processes your Customer Account Data and your Customer Usage Data, Smilie is acting as a controller. We are also a controller for our employees’ personal data. When Smilie processes your Customer Content, we are acting as a processor.
If you are a visitor to our website, or if you are not a Smilie user and you are attending one of our events, we collect a minimal amount of data about you (depending on how much you’ve chosen to share with us). This might be as little as an IP address or a cookie, and it might be your contact information. We also consider this Customer Account Data.
If you are an end user of a Smilie customer, this Privacy Notice does not apply to the services that our customers provide to their end users. Our customers have their own policies regarding the collection, use, and disclosure of the personal data of their end users. If you are an end user of one of our customers and want to learn about how that customer handles your personal data, we encourage you to read the customer’s privacy policy. Only the customer can assist you with requests for access or deletion.
Data about our customers
In short, Smilie requires the minimal amount of data necessary to provide services to you, and the amount or type of data we collect depends on the product or service you choose or how you use it. If you choose to share additional information with us so that we can better customize your account and our services, we’ll process that with the same care and respect. We do not sell your personal data and we do not share your information with third parties for those third parties’ own business interests. This Privacy Notice describes the data we collect from our customers at a high level.
We use the information we collect and share it with our service providers primarily to provide the services you’ve requested from us, and as needed for our operational purposes (e.g., to do the things we need to do to function as a business, such as to collect payment). In addition, we may use data about our customers to detect, prevent, or investigate security incidents, fraud, or abuse and misuse of our platform and services.
Data we process during account creation and account usage
When you sign up for an account with us, we ask for certain information like your contact details and billing information to facilitate payment and communication. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on Smilie makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.
Information You Share Directly:
Name and contact information. When you sign up for a Smilie account with us, we will ask you to give us your name, email address, phone number and your company name, and to create a password. You can also name your account (or accounts, if you have more than one). We collect this information so we know who you are — this helps us communicate with you by email, text or voice call about your account(s), service-related information, recognize you when you communicate with us through the account portal or otherwise, bill you correctly, and provide other services.
Payment information. We’ll ask you to provide our payment processor with your payment method information like a credit card or your Paypal account and your billing address. Our payment processor, acting on our behalf, gathers this so we can bill you for your use of our products and services. Our payment processor will share your billing address with Smilie. We’ll also use your billing address for tax calculation and audit purposes.
How Long We Store Your Customer Account Data
Smilie will store your Customer Account Data as long as needed to provide you with our services and to operate our business. If you ask Smilie to delete specific personal data from your Customer Account Data, we will honor this request unless deleting that information prevents us from carrying out necessary business functions, such as billing for our services, calculating taxes, or conducting required audits.
More specifically, within 60 days following closure of your account, we will either delete other Customer Account Data or transform it such that it can no longer be used to identify you, with the following exceptions, depending on and in accordance with applicable law:
- Customer Account Data is stored for up to seven years following closure of your account. However, we may retain invoice records, including their digital equivalent, for longer periods for accounting, tax, and audit purposes.
- Where we collect subscriber records, we will retain this data for such time as needed for legal, security and anti-fraud purposes.
- We may retain your communications with Smilie’s Customer Support Teams for up to three years after your account is closed.
- We may need to retain data due to special circumstances (such as due to an open investigation, audit, or other legal matter).
Data about our customers’ end users
What Customer Usage Data and Customer Content Smilie Processes and Why
- We use Customer Usage Data and Customer Content to provide services to you and to carry out necessary functions of our business as a communications service provider. We do not sell your end users’ personal data and we do not share your end users’ information with third parties for those third parties’ own business interests or cross-context behavioural advertising.
- The particular end user personal data Smilie processes when you, our customer, use our products and services, and the reasons Smilie processes end user personal data, depends on how you use our products and services and which Smilie products and services you use. In many cases, you can opt to store records of your communications or other activities in your Smilie account, and these records may include your end users’ personal data. You may also have the option to use additional features or tools within Smilie’s products or services that allow you to do things such as analyze the records, including end user personal data, in your Smilie account. In those cases, Smilie will process this information to provide you with the service you request.
Where and What Information you or your end users share directly:
Name and contact information.
- When your end user claims a gift, at the checkout page and we will ask for the name, email address, phone number and address (optional)
- When you set a campaign, we will ask for the name, email address (optional), phone number (optional).
How Long We Store Customer Usage Data and Customer Content
As a Smilie customer, if the Smilie product or service you use enables you to store records of your usage on Smilie, including personal data contained within those records, and you choose to do so, then Smilie will retain these records for as long as you instruct, up until termination of your account. In some cases, use of extended storage may cost more. If you later instruct us to delete those records, we will do so. Please note that it may take up to 30 days for the data to be completely removed from all systems.
How Smilie shares our customer and customer’s customer data.
We do not sell your personal data or the personal data of your end users. We also do not allow any personal data to be used by third parties for their own marketing purposes (except in cases where you explicitly request or provide consent for us to do so, such as at a conference when you direct us to share your information with a sponsor) or share personal data for cross-context behavioral advertising. However, we do need to share personal data in order to provide our products and services to you and your customers, such as but not limited to arrange for a delivery, change of choice in gift, sending of voucher codes.
We’ll share your personal information or your customer’s personal information within the Smilie and with our Business Partners, for any of the purposes set out below.
- Within Smilie to facilitate the conduct of our business, carrying out our business activities and servicing you in relation to fulfilling the engagement event;
- Our third-party service providers, sub-contractors of third-party service providers, contractors and vendors – which could include but not limited to logistics provider, retail stores, digital card vendors, third-party service providers and sub-contractors of such third-party service providers which may assist us in carrying out our business activities in fulfilling the engagement event;
Consent
By using our website, you hereby consent to our Privacy Policy and agree to its terms.
Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
Log Files
Smilie follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
Cookies and Web Beacons
Like any other website, Smilie uses “cookies”. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
Advertising Partners Privacy Policies
You may consult this list to find the Privacy Policy for each of the advertising partners of Smilie.
Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Smilie, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
Note that Smilie has no access to or control over these cookies that are used by third-party advertisers.
Third Party Privacy Policies
Smilie’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Smilie does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.
Contact Us
If you have any questions or comments regarding our privacy practices, you can contact our Data Protection Officer at:
Name: Mrs Wee Leng Tay, Chief Data Protection Officer
Email: [email protected]
Address: 6001 Beach Rd, #11-09 GOLDEN MILE TOWER, Singapore 199589
