This Privacy Notice for Customers (“Privacy Notice”) aims to explain how Smart Axiata Co., Ltd. (“Smart”, “us”, “we” or “our”) collects, stores, uses and discloses (collectively referred to as “process”) when you subscribe to our products or services, use of our applications, or visit our websites.
1. Our Principles. All our activities are underpinned by our T.R.U.S.T principles of being Transparent, respecting your Rights, in our Use of your personal data, through robust cyber Security practices and we take due care when Transfer of your personal data is required.
2. Collection of Personal Data
- 2.1. The types of personal data we may collect about you include:
- a) contact information (such as name, address, email address and telephone number);
- b) identification information (such as passport/identity card, visa, photograph, age and gender);
- c) sensitive information (such as health condition and financial details);
- d) product-specific information (such as preferences, closed user groups (CUGs), friends and family who you choose to include in your service plan and credit limit);
- e) IT information (such as IP addresses, logins, GPS locations, CCTV footage and cookies); and
- f) service account information (such as call usage, account balances, transaction history, credit information and billing).
- g) biometric and facial recognition for e-SIM registration.
- 2.2. We collect your personal data when you:
- a) use Smart’s products and services that are offered;
- b) make customer enquiries and register for information or other services;
- c) interact with Smart’s website and social media pages (such as SMS, emails, questionnaires and surveys);
- d) participate in Smart’s promotional events, incentive/loyalty programs, contests or prize-winning activities; and
- e) provide information through our contact center, dealers, sales channels and any other affiliates.
3. Use of Personal Data. Your personal data may be used or processed by us for the following purposes:
- a) to provide you with our products, services and/or offers which may be of interest to you;
- b) to notify you about benefits and changes to the features of our products and/or services;
- c) to provide you with our services, campaigns and/or promotions;
- d) to use your information for participation in our customer surveys or events; and
- e) to send information about products/services offered by selected third parties that you may be interested in.
4. Information about Children. If you are under the age of 18, you are required to obtain the consent of your parents or legal guardian before using our network, products and/or services.
5. Disclosure of Personal Data. We keep your personal data confidential and do not share it with any third party or government authority, except under the following circumstances:
- a) to meet our legal and regulatory obligations, including to prevent and/or detect crime;
- b) to enforce and/or safeguard our rights, usage terms, intellectual/physical property, our safety or of associated parties;
- c) if we are acquired by or merged with any other company; or
- d) for any legal claim, where we are required to do so.
6. Cross Border Data Transfer. We do not sell, trade, transfer or otherwise share your personal data, except:
- a) within Axiata Group, where necessary and within the limits of applicable laws:
- b) as required by law, such as in conjunction with government inquiry, litigation or similar legal processes;
- c) with other carriers and operators when routing international calls;
- d) with our service providers, agents and contractors who work on our behalf; and
- e) with our subsidiaries, affiliates, agents, distributors and dealers.
7. Security of Personal Data. We have implemented various physical, technical and administrative security measures to protect your personal data and our network from unauthorized access. Some of these measures include:
- a) encryption of data in transit or at rest;
- b) strict adherence to privacy and security practices; and
- c) periodic security assessments and reviews to upgrade our practices.
8. Retention of Personal Data. We will retain your personal data for as long as it is required for business, tax or legal purposes. Post that, we take measures to either delete or anonymize your personal data. You may also request for a deletion of your personal data that you voluntarily provided through Facebook Messenger by providing your full name, phone number and the request in writing to the email provided in Clause 9 hereunder.
9. Data Subject Rights
We respect your rights and privacy by taking steps to ensure that your personal data is accurate and up to date.
- a) you have the right to know that personal data we have about you;
- b) you have the right to request a copy of your personal data. Personal data requested has to be specific and limited to what you have submitted to us when you register for your services; and
- c) you have the right to correct your personal data to ensure it is accurate, complete and up to date.
For exercising your rights, you can reach out to us through the details under contact us section given below.
10. By submitting personal data to us, acknowledge that:
- a) you have read and understood this Privacy Notice and agree and consent to the use, processing and transfer of personal data as set out herein; and
- b) all information and representation provided are true and correct to the best of your knowledge, and you have not knowingly omitted any relevant information which may have adverse effect.
11. Updates to the Privacy Notice. We reserve the right to update this Privacy Notice as and when the need arises. We recommend you to revisit this Privacy Notice from time to time to stay informed of any changes.
12. Contact Us. If you have any questions or complaints about this Privacy Notice or our privacy and information handling practices, you can contact us at [email protected]
This notice was last updated on 02/10/2023
