Privacy Notice

Smart Axiata Co., Ltd. (herein collectively referred to as “Smart”, “us”, “we” or “our”) understand that your privacy is important and we are committed to protecting the personal data of our customers, business partners, visitors, employment candidates, employees and of individuals who work for, or act on behalf of our customers and/or business partners (collectively referred to as “data subject”) that has been provided to us. All our activities are underpinned by our T.R.U.S.T principles of being Transparent, respecting 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.

This Privacy Notice aims to explain how Smart collects, stores, uses and discloses (collectively referred to as “process”) your personal data.

This notice applies to all data subjects who interact with Smart products and services including all Telecom services, Value added services, applications and websites. Please note that this notice should be read together with product/service specific terms and conditions. When accessing certain services provided in partnership with third parties, customers may be redirected to the partner’s account or platform. We encourage customers to review the partner’s privacy notice, as their data processing practices may differ from ours.

If you provide us with personal data of another individual, you hereby represent that you have obtained consent from that individual prior to providing their personal data to us. References to ‘your personal data’ in this Privacy Notice would include such individual’s personal data that you provide to us.

Information about children

If you are under the age of 18, you are required to obtain the consent of your parent, guardian or person who has parental responsibility over you before providing us with your personal data (for example, your name, address and email address).

What personal data do we collect?
The types of personal data we collect or obtain may vary according to our relationship with data subject and may include the following:

For customers

contact information (such as name, address, email address and telephone number).
identification information (such as passport/national identity card, visa, photograph, age and gender).
financial information (such as account number and credit card/debit card number).
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).
IT information (such as IP addresses, logins, GPS locations, and cookies).
service account information (such as call usage, account balances, transaction history, credit information and billing).
biometric (live photo for validation during SIM registration).
any footage captured or recorded by our surveillance camera (CCTV) system.
any recordings of calls placed by you to our customer care center.

For Business Partners and Suppliers

contact information (such as name, address, email address and telephone number etc.).
identification information (such as national identity card, passport, driver's license, date of birth, IP addresses, internet cookies etc.).
business information (such as name of organization, name of the employer, job title, department, business registration documents etc.).
Financial information (banking information).
any footage captured or recorded by our surveillance camera (CCTV) system.

For Visitors (to any of our Premises/Offices)

contact information (such as name, company name, address, email address and telephone number).
identification information (such as passport/identity card number).
reason for visit.
date and time you enter or leave.
security notes (special instructions and access restrictions) and times swipe-in/out of the building.
video footage which shall be recorded on our CCTV system installed at our premises.

For Employment Candidates

personal details (such as name, age, address, photograph, telephone number, and email).
recruitment information (such as application form (website and paper), CV, interview notes video interviews, references from previous employees).
sensitive information (such as health check, disability, trade union membership, existing salary and allowance).
credential information (such as username and password for our recruitment portal).
identification information (such as passport/identity card, date of birth and place of birth).

When do we collect your personal data?
We may collect or obtain your personal data:

For customers

when you purchase and use Smart’s network, products and services (including through Smart shops, dealers, website, SmartNas and sales channels).
when you make customer enquiries and register for information or other services.
when you interact with Smart’s website, digital applications and social media pages.
when you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).
when you participate in Smart’s promotional events, incentive/loyalty programs, contests or prize-winning activities.
from our surveillance camera (CCTV) system.

For Business Partners and Suppliers

when you enter into an agreement with us to carry out any kind of business activity.
when you use our network, products and/or services.
when you communicate with us (such as via telephone calls, text messages or other digital channels, emails, questionnaires or surveys).
when you use or interact with any of our digital applications, visit any of our websites or social media pages.
from our internal database pursuant to your relationship with any subsidiary, affiliate or associated company.

For Visitors (to any of our Premises/Offices)

when you use our network, systems and/or services.
when you use our network, products and services.
when you provide us with your identification document(s).
when you provide your host with information; and
from our surveillance camera (CCTV) system or any other recording system.

For Employment Candidates

when you directly send in your job application.
when you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).
from your referee.
from your previous employer(s).
from anyone with whom you may have or had a business relationship with.
from your or our recruiter, recruitment agency or recruitment website/platform.

How do we use your personal data?
Your personal data may be used or processed by us for the following purposes:

For customers

to provide you with our products and/or services that you have subscribed to.
to notify you about benefits and changes to the features of our products and services.
to provide you with our latest offers, campaigns and/or promotions.
to send you service messages about our subscription or account registration.
to comply with laws and legal, contractual obligations and protecting or exercising our legal, contractual and/or regulatory rights and remedies.
to send information about products/services offered by our group of companies, subsidiaries, associates/affiliates and selected third parties that we think may interest you. (you may unsubscribe from such messages).
to respond to complaints or account enquiries.
to use biometrics and identity cards to verify your true identity and avoid any kind of fraud during SIM registration, update, correction, change and transfer.
to undertake market and product analysis based on your use of our products and/or services (achieved by analysing your service preferences) and for product and/or services enhancements and improvements.
for other legitimate purposes.

For Business Partners and Suppliers

for business execution.
for organization and management of the business.
for health, safety, and security.
for compliance with laws and/or contractual and/or regulatory obligations.
for protecting or exercising our legal, contractual and/or regulatory rights and remedies.
for protecting our assets and interests.
for other legitimate purposes.

For Visitors (to any of our Premises/Offices)

to maintain and report internal records.
to facilitate access and visit in an efficient manner.
to ensure that physical security of people (employees, visitors and contractors) and items along with security if confidential information located/accessible in our premises is maintained.
to comply with laws and/or contractual and/or regulatory obligations.
to protect or exercise our legal, contractual and/or regulatory rights and remedies.
for other legitimate purposes.

For Employment Candidates

for identifying and evaluating your potential employment or future roles that may become available.
for record keeping in relation to recruiting and hiring.
for ensuring compliance with legal and regulatory requirements.
for conducting background checks, as permitted by the applicable law.
for protecting our legal rights to the extent authorized or permitted by law.

Who do we disclose your Personal Data to?

We keep your personal data confidential and do not share it with any third party or government authority, except under the following circumstances:

For customers

to our group of companies, subsidiaries and associates/affiliates.
to other carriers and operators when routing international calls.
to third parties when disclosure is necessary or reasonable to protect our rights, protect your security, investigate fraud or respond to a law enforcement request.
to our service providers, field engineers, contractors, subcontractors or any other third-party performing work on our behalf or at our instruction.
to any public authority, governmental, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subjected to or as permitted by applicable law.
to our business partners for the delivery of new product/service, which you have consented to/not opted out of.
to verify identity, conduct credit checks, and manage fraud risks with authorized third parties and financial institutions.
to any parties that act as our payment channels, including to validate your information, as and when required.
to third parties for research and development purposes.
if we are acquired by or merged with any other company.
to third parties for the purposes set out under “How do we use your personal data?”.

For Business Partners and Suppliers

to our group of companies, subsidiaries and associates/affiliates.
to our third-party agents, service providers, consultants, advisors, auditors, contractors and/or subcontractors.
to any public authority, governmental, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subjected to or as permitted by applicable law.
if we are acquired by or merged with any other company.
to third parties for the purposes set out under “How do we use your personal data?”.

For Visitors (to any of our Premises/Offices)

to meet our legal and regulatory obligations, including to prevent and/or as permitted by applicable law.
to implement various physical, technical and administrative security measures.
for any legal claim, where we are required to do so.

For Employment Candidates

to meet our legal and regulatory obligations, including to prevent and/or detect crime.
to enforce our rights, usage terms, intellectual/physical property, our safety or of associated parties.
if we are acquired by or merged with any other company.
for any legal claim, where we are required to do so.

We only provide our service providers, partners or authorized third parties with the information strictly required to perform their respective duties. We use reasonable efforts in accordance with industry best practices to ensure that the above-mentioned maintain the confidentiality of your personal data and are restricted from using personal data for any unauthorized purpose.

Transfer of Personal Data

We do not sell, trade, transfer or otherwise share your personal data, except when necessary to meet our business, legal or service obligation. Where your personal data has been transferred to the members of our group of companies, any subsidiary, affiliate/associate and/or to third parties located outside of Cambodia, the transfer of your personal data will be carried out under organizational, contractual and legal measures within the scope of existing laws and regulations. There will be adequate levels of protection implemented as well as in compliance with any additional local legal requirements for the parties receiving this information in order to safeguard your personal data.

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:

encryption of data.
strict adherence to privacy and security practices.
periodic security assessments and reviews to upgrade our practices.

We are committed to safeguarding your information using various security controls. However, we cannot guarantee absolute security in this ever-evolving digital landscape. We encourage you all to take necessary precautions when using and sharing personal information online.

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.

Data Subject Rights

We respect your rights and privacy by taking steps to ensure that your personal data is accurate and up to date.

you have the right to know what personal data we have about you.
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.
you have the right to correct your personal data to ensure it is accurate, complete and up to date.
you have the right to withdraw your consent from our processing of your personal data (you may withdraw by unsubscribing to the services/product via SmartNas app, using USSD code or visiting nearby smart shop).
you can also ask us to restrict how we use your personal data where it is likely to cause damage or distress.
you have a right to prevent processing of your personal data for the purposes of direct marketing.
you may also request for a deletion of your personal data that your voluntarily provided through Facebook Messenger by providing your full name, phone number and the request in writing to the email provided below.

For exercising your rights, you can reach out to us through the details under contact us section given below or visit our nearby Smart shop. Please note that we will be able to fulfill your request within the scope of our policies and as permitted or required by law.

Voluntary and obligatory supply of personal data

Unless otherwise specified in this Privacy Notice, your supply of personal data is voluntary. If you fail to supply personal data, this may result in the consequences described in the following section.

Consequences of not providing personal data

We may require collection of certain personal data about you and failure to provide such information may:

result in us preventing your entry to our premises or participating in our events.
result in us being unable to process your application and/or provide you with our services.
result in us being unable to respond to your requests on our products/services.
limit or prevent access to certain features on our website/weblinks.
result in us being unable to inform you of the latest updates regarding any promotions, our services/products or launches.
result in your inability to receive invitation to promotional activities organized by us.
negatively affect our ability to communicate with you.
result in our inability to enter into a contract with you or a counterparty or continuing to contract with you or counterparty.
negatively impact your chances of being selected for any potential employment, engagement or internship.

By submitting personal data to us, you acknowledge that:

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
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.

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.

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 23/10/2025

Recent privacy notice updates