Privacy Notice

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. 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.

8. 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.

9. 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 16/11/2022

By entering our premise, you are deemed to have agreed to the following Privacy Notice for Visitors (“Privacy Notice”) which aims to explain how Smart Axiata Co., Ltd. (“Smart”, “us”, “we” or “our”) collects, stores, uses and discloses (collectively referred to as “process”) your personal data.

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 data is required.’

2. Collection of Personal Data. The types of personal data we may collect include:

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

3. Use of Personal Data. We use or process your personal data for the following purposes:

• a) to maintain and report internal records;
• b) to ensure that physical security of people (employees, visitors and contractors) and items along with security of confidential information located/accessible in our premises is maintained;
• c) to record and control access into our premises and security; and
• d) to comply with legal and regulatory requirement.

4. 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 implement various physical, technical and administrative security measures; or
• c) for any legal claim, where we are required to do so.

5. 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.

6. 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 24/05/2021

This Privacy Notice for Candidates (“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”) your personal data.

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 data is required.

2. Collection of Personal Data
2.1. The types of personal data we may collect include:

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

2.2. We may collect your personal data from you, your named referees, employment agencies and databases, publicly accessible sources, your social media accounts; and by using cookies.

2.3. If you provide us with personal data of other individuals as part of the application process, you confirm that you have obtained their prior consent for us to process and contact them, as deemed necessary.

3. Use of Personal Data
Your personal data may be used or processed by us for the following purposes:

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

4. Process of Personal Data
4.1. The following persons/entities are authorized to access your personal data:

• a) our internal functions/teams and those of our affiliated entities;
• b) local or international third parties for relevant legal or business purposes; or
• c) government authorities or courts if we have to or as authorized by law.

4.2. We may transfer your personal data to another country (including to a company within Axiata Group) in accordance with applicable laws and where there are adequate personal data protection procedures in place.

5. Disclosure of Personal Data
We keep your personal data confidential and do not share it with any third party or government authority, except when we have your consent or under the following circumstances:

• a) to meet our legal and regulatory obligations, including to prevent and/or detect crime;
• b) to enforce 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. Retention of Personal Data. We will retain your personal data for as long as it is required for business, tax or legal purposes. If you accept our offer of employment, the personal data collected during your candidature will become part of your personnel records, to be retained throughout and for a period after your employment with us. If we do not employ you, we may nevertheless continue to retain and use personal data collected during the recruitment process in order to consider you for new positions, and, if appropriate, to refer back to an earlier application if you submit a resumé or other information to us again in the future, as well as for system administration to perform research and analysis.

7. Updates to the Privacy Notice. We reserve the right to update this Privacy Notice, as and when need arises. We recommend you to revisit this Privacy Notice from time to time to stay informed of any changes.

8. 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 24/05/2021