Privacy Statement
smart Privacy Statement
smart group entities and their affiliates (collectively referred to as "smart", "we", "our" or "us") highly value your personal data protection. These entities include:
COLMOBIL LTD, located at 20 Ha’Amal St., Rosh-Ha’Ayin 8092, Israel, for users accessing our services within Israel.
Fu Chong Motors (Hong Kong) Company Limited, located at 25th Floor, Devon House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong SAR, China, for users accessing our services within Hong Kong SAR, China.
Fu Chong Motors (Macau) Company Limited, located at Avenida Dr. Sun Yat Sen n°s 252 – 266, Edifício Chun U Villa, r/c, Loja A, B e C, Taipa, in Macau SAR, China, for users accessing our services within Macau SAR, China.
Cycle & Carriage Engineering Pte. Ltd., located at 239 Alexandra Road, Singapore 159930, for users accessing our services within Singapore.
[smart Mobility Australia PTY Ltd.], located at [21 Dorset Road, Northbridge, NSW 2063., Australia], for users accessing our services within Australia.
[Comercial Kaufmann S.A], located at [Av. Gladys Marin 5830 Estación Central Santiago 9190205 Metropolitana de Santiago (ex Región XIII) Santiago Chile], for users accessing our services within Chile.
PROTON NEW ENERGY TECHNOLOGY SDN. BHD., located at Centre of Excellence, KM33.8 Westbound Shah Alam Expressway, 47600, Subang Jaya, Selangor, Malaysia, for users accessing our services within Malaysia.
smart Automobile NZ Limited, located at 61 Mountain Road, Mt. Wellington, Auckland 1072, for users accessing our services within New Zealand.
INCHCAPE COLOMBIA S.A.S., located at Cra 70 #99A-00 – Bogotá – Colombia, for users accessing our services within Colombia.
Autolider Uruguay S.A., located at Rambla Baltasar Brum 3028, Montevideo 11800, Uruguay, for users accessing our services within Uruguay.
AUTOLIDER ECUADOR S.A.S., located at 10 de Agosto N36-226 - Naciones Unidas, Ecuador, for users accessing our services within Ecuador.
Prestige Auto S.A.U., located at 2867 República de la India, 1st Floor, City of Buenos Aires, Argentina, for users accessing our services within Argentina.
Autostar Vehículos, S.A., located at La Uruca, in front of Banco Nacional. San Jose, Costa Rica, for users accessing our services within Costa Rico.
Thonburi Stardust Co., Ltd., located at 84/1 Viriyaphant Building, 2nd floor Charan Sanitwong Road, Bang Phlat, Bangkok, Thailand, for user accessing our services within Thailand.
This privacy statement aims to describe, in a concise, clear, and easy-to-understand manner, how smart collects, uses, discloses, and manages your personal data.
This privacy statement applies to smart's website, social media accounts, applications, Internet of Vehicles services, and other services provided by smart.
Please note that this privacy statement applies to users in Hong Kong Special Administrative Region, Singapore, Macau Special Administrative Region, Israel, Australia, Chile, Malaysia, New Zealand, Colombia, Uruguay, Ecuador, Argentina, Costa Rica and Thailand (hereinafter collectively referred to as the "Applicable Market"). Specific products and services may be subject to separate privacy statements. The collection and use of your personal data may vary depending on the specific products, services, and your country or region. The actual circumstances will apply.
If you have any questions about the data processing practices outlined in this privacy statement, please contact us to address your specific concerns.
1. WHAT DATA WE COLLECT
1.1. Interaction before Sale (Including the Registration Stage)
1.1.1. Account Registration
Based on your consent and contracts signed with you, you will provide information such as email and nickname to create a smart ID account. This account becomes your identity in the smart Ecosystem, enabling you to enjoy smart connected services, including vehicle settings, in-car connectivity, generating vehicle digital keys, and other online services provided by smart. For more detailed information about smart Ecosystem, please read “HOW WE SHARE YOUR DATA” section.
1.1.2. Interaction with you
Based on your consent, contracts signed with you, or other legal basis, when you contact us for inquiries, seek support, or provide feedback, we need to collect your contact information (name, address, email, phone number, contact preferences, etc.) and the information involved in your communication or interaction with us. This is to facilitate future communication, confirm your needs, and respond to your inquiries or response your concerns.
1.1.3. Cookies
When you visit our website, we use essential cookies to provide you with a service you have requested or when this is necessary for the functioning of our website. If you opt in, we also use optional analytical and marketing cookies in accordance with local law. Before doing so, we will ask for your consent through a popup window, which will save your decision on your device. This allows us to collect and store certain information about website visits to help us understand, for example, how many visits our website receives, which pages are the most popular, and how many customers receive error messages, etc. Consent, refusal, or deletion of cookies is associated with the device and the web browser you use; managing cookies and cookies preferences must be done within your browser's options/preferences.
If you decide to reject our use of cookies or delete them, you may not be able to access all features of our website, or some features may be restricted. For more detailed information about cookies and instructions on how to set your browser to accept, reject, or delete cookies, please refer to www.allaboutcookies.org.
1.2. When you Become a smart Customer
1.2.1. Energy Management Data
1.2.1.1. Charge-Discharge Services
To help you optimize energy usage, improve vehicle efficiency, and enhance the driving experience, we provide an energy management system. You can choose the time to charge the vehicle battery at a charging point, set the vehicle's air conditioning and battery pre-heating functions based on the expected departure time, improving the vehicle's efficiency at startup and enhancing driving comfort.
During the energy management process, we collect and use some key data, including driving time, estimated range, state of charge (SOC), charging status, charge limit, remaining charging time, air conditioning pre-heating, battery pre-heating, smart ID, energy consumption, and power consumption, etc. The comprehensive analysis of this data helps optimize energy usage, improve vehicle efficiency, and provides you with personalized energy management solutions to meet your individual driving needs and preferences.
1.2.1.2. Scheduled Charging Service
We offer scheduled charging service, so that you can easily set a charging time, flexibly arrange the vehicle's charging time, and ensure charging is completed during periods of lower electricity costs or greater convenience. Based on this, we need to collect the following information regarding your scheduled charging service: scheduled charging start time,scheduled charging end time and priority charge to battery limit (Yes/No).
1.2.2. Vehicle Communication Data
1.2.2.1. Communication
If you wish to use communication functions such as making and receiving calls through in-car devices by connecting your mobile device, you can choose to sync information such as contacts, call records, and text messages from your phone to the car. In this case, we will collect the above information. If you do not plan to use this function, you can choose to refuse synchronization, and in this case, we will not collect the mentioned information.
1.2.2.2. Emergency Contacts
For safety purposes, when you encounter safety events (such as collisions, airbag deployment, or automatic emergency braking events) and we cannot contact you personally, we may need to contact your emergency contacts to complete the safety event response work and protect your safety. If you are unwilling to provide us with your emergency contact information, you can also fill in your own phone number or an invalid phone number in the emergency contacts section, but this will affect our response to your safety event.
1.2.3. Vehicle Driving Data
1.2.3.1. Online Navigation
We need to collect your location information to support in-car map and navigation functions. Location services may use a combination of GPS, Bluetooth, IP addresses, Wi-Fi, and mobile towers to determine your location. To facilitate navigation to frequently used destinations (such as home or work), we also record information such as the navigation favorites you enter and historical search records.
In addition, to provide the Kika navigation service, we entrust Shenzhen Xinmei Hutong Technology Co., Ltd. with processing your terminal hardware virtual ID (XDSN) to activate the license, as well as processing your system language settings, current location, and start and destination latitude and longitude information to provide real-time navigation, route planning, map display, and POI search functions. You can store frequently used addresses (such as home and work addresses) on the vehicle, and this information will not be uploaded to the cloud.
For privacy protection, all information related to these functions is processed locally, and smart cannot access it. For safety purposes, when you encounter safety events (such as collisions, airbag deployment, or automatic emergency braking events), we may use your vehicle's location to assist in response work. This means that, unless for safety event response, we will not link your location with you or know where you have been.
1.2.3.2. Driving Assistance (Cameras)
We use camera suite to provide advanced features such as reverse guidance, high-level navigation, and automatic parking. To protect your privacy, we do not capture continuous recordings, and real-time camera content cannot be viewed by smart. Live cameras are end-to-end encrypted and cannot be accessed by smart. Video information collected by cameras with storage functionality is only stored on local USB drives and is not transmitted to smart.
1.2.3.3. Driving Assistance System
When you use the driving assistance features, the vehicle sensors need to process the following data in real time: radar data, assisted driving communication data, vehicle status data (abnormal status, fault information, diagnostic trouble codes, gear position, speed, acceleration, steering angle, pedal status, door status, hood status, seatbelt status), driving mode, assisted driving system logs, assisted driving algorithm operation logs, and vehicle calibration parameter data (camera parameters, radar parameters, inertial navigation parameters) in order to provide you with driving assistance functions. The aforementioned data is deleted immediately after processing in the vehicle. We do not store, transmit, or process this information in any other way.
1.2.3.4. Driving Assistance System Data Diagnostics
When you use driving assistance features and enable the "Remote Vehicle Diagnostics"-"Settings" -"Privacy" section of the vehicle's central display, you authorize the upload of driving assistance system-related data collected by vehicle sensors to the cloud. This data will be transmitted to qualified partners for the purposes of developing driving assistance functions, diagnosing issues, and optimizing upgrades. During this process, we will request access to your vehicle's external cameras and radar. Image data captured by external cameras will be blurred (processed locally by the vehicle system). You can disable the data diagnostics feature at any time in your vehicle settings.
1.2.3.5. Driver Drowsiness and Attention Warning System (DDAW)
To prevent accidents caused by fatigue driving, we provide DDAW that assesses your alertness and issues warnings when necessary. For this, we will use the vehicle status data (speed, gear data, turn signal) and live camera to analyze your facial features in real time, including the opening and closing of eyelids, duration of closed eyes, blink frequency, etc. Live Camera is end-to-end encrypted, and we will not store, transmit, or otherwise process this information.
1.2.3.6. Driver Distraction Detection System
To ensure your driving safety, we provide a driver distraction detection function that assesses your gaze direction when the co-driver display is active and issues warnings when necessary. We analyze your gaze direction in real time using vehicle status data (speed, gear position, and co-driver occupancy signal) and the in-cabin camera. All such information is processed locally, and we do not store, transmit, or process this data in any other way. You can disable this feature at any time in your vehicle settings.
1.2.4. Vehicle Management Data
1.2.4.1. Vehicle Settings
Our vehicle configuration feature offers you various convenient operations:
∙ To enable SIM card connectivity for network services, we need to collect the VIN (Vehicle Identification Number), smart ID, remote parking key, and SIM card identification information.
∙ In user profile settings, you can create a personal profile and store preference settings such as body adjustments, ambient lighting, air conditioning, keyless unlock, and ergonomic settings (seats, mirrors, head-up screen) and vehicle nickname. These settings are linked to smart ID, and when you log into the vehicle, your profile settings and additional information provided in the smart ID account, such as profile photos, name, birthdate, etc., will be loaded.
∙ We support over-the-air (OTA) updates, allowing information and entertainment systems and electronic control unit (ECU) firmware to be updated online for new features, bug fixes, and error corrections.
∙ Additionally, we provide remote control functionality, allowing you to manage and control the vehicle through Hello smart International App. Accordingly, we will collect vehicle status information, including charge lid status (open/closed), frunk lock status, vehicle door lock status, vehicle windows status, trunk status , vehicle light status, honking status, air conditioning operation status, air conditioner temperature, in-car temperature, driver’s seat ventilation and heating status, passenger’s seat ventilation and heating status, steering wheel heating status, PM2.5 concentrations inside the vehicle (subject to the actual display in the Hello smart International App's remote control interface). To enable you to view your vehicle’s location through Hello smart International App, we will request access to your vehicle’s location permissions to collect its real-time position and request access to your mobile device’s location permissions to determine your phone’s location. We will display the real-time distance between you and your vehicle within Hello smart International App for convenient tracking. We only record the current state of the aforementioned information. Historical data will be automatically overwritten and deleted in real time.
Upon the first startup, we offer to help you complete the in-car system setup. Depending on your choice, we also support one-touch adjustment to preset scenarios. For a more convenient control experience, you can control the in-car system through gestures, and the in-car system also has features like connecting to mobile hotspots, making the entire driving process more intelligent and convenient.
1.2.4.2. Voice Control
You can use voice control to interact with the vehicle, allowing you to interact with the vehicle through voice commands. With voice control, you can easily issue commands, such as adjusting the seat, turning on the air conditioning, and navigating to a destination.
Throughout the process, we emphasize privacy protection, ensuring that your voice data is securely protected and not used for other purposes. To protect your privacy, the transcription of your voice will not be associated with your account or VIN.
1.2.4.3. CarPlay
CarPlay provides a convenient device connection experience, allowing your smart device to interact easily with the vehicle through Bluetooth.
1.2.4.4. Vehicle Security
We integrate vehicle security-related data, including geographical location, VIN, door lock and hood lock status, usage patterns, charging status, remaining charging time, high-voltage status, charging current, charging voltage, charging start time, and vehicle status data (mileage, battery voltage, door and window status, vehicle alarm status, etc.), ensuring the functionality and integrity of the vehicle's electronic components to protect the vehicle itself, drivers, and passengers. Additionally, we equip the vehicle with an anti-theft system to prevent unauthorized starting of your vehicle. If the anti-theft system is enabled, it will continuously monitor the vehicle's status and trigger an alarm when doors/trunk are opened illegally.
1.2.4.5. Vehicle Diagnostics
smart vehicles are equipped with an advanced remote safety monitoring system, designed to comprehensively collect and store data from various vehicle systems to support remote vehicle diagnostics, fault detection, maintenance warnings, fault and quality analysis, and vehicle safety monitoring. The covered data includes VIN, location and motion data (such as time, location, speed, direction, pedal), vehicle maintenance data (next service due date), environmental information (temperature, air pollution), electric motor, high-voltage battery and alarm information, vehicle location data (latitude and longitude data), and door and hatch status/location/locking status, etc. This data is used for remote fault diagnosis, fault finding and resolution, maintenance warnings, warning analysis, safety checks, optimization of functions, and judgment of battery faults. Additionally, you can access the data for vehicle maintenance and on-site inspection operations when needed, ensuring the reliability and safety of the vehicle, providing you with comprehensive vehicle status monitoring and maintenance services, and ensuring the stability and safety of the vehicle during driving.
1.2.4.6. Vehicle Digital Key
We provide the vehicle digital key feature, allowing you to start and lock the car with a single click through the Hello smart International App. To generate the digital key, we collect your smart ID, VIN, and series code information to bind your system identification with the vehicle. Additionally, you can share the digital key with others through the App. In this case, we also need to collect the recipient's information (such as email) to display a popup to the recipient with information about the sharer and the shared vehicle. If the recipient chooses to accept, he/she will have full access to the vehicle. Hello smart International App retains a history of your shared digital keys.
Furthermore, when you activate the vehicle digital key feature, we will request your location permission and Bluetooth permission to bind the vehicle’s digital key. At the same time, during your use, we will continue to request your location permission in the background within the necessary scope to ensure the link between the App and the vehicle, and ensure the normal realization of digital key function.
Please note that the Hello smart International App will never read or store your location through the location permissions in this case. The location permission request is solely used for the purpose of enabling the Bluetooth connection, ensuring the vehicle digital key functionality.
1.2.4.6. Weather Service
When you use the weather service, we will collect your vehicle's approximate location to provide weather information corresponding to your vehicle's current area.
1.2.5. In-Car Entertainment Data
1.2.5.1. Media
Our media is designed to provide a rich audio and video entertainment experience, covering various functions and connection methods to meet your personalized media needs. We offer you a convenient and personalized music and video selection experience. You can log in to use the online music or video function by scanning the QR code or entering your username and password in the third-party multimedia service interface to connect to the third-party application multimedia service installed in your vehicle.
You can use the radio station radio service, as well as input audio using Bluetooth connectivity and USB port connectivity. In the video feature, you can select your country from a country list, and we will recommend popular local video content based on your country location and usage habits. We do not store your streaming service account information or browsing history.
In the process of implementing these functions, we collect some specific media data, such as personal favorites of the radio (not linked to smart ID), records of your consent to authorize third-party applications, device identification information, VIN, and your approximate location. Additionally, to provide you popular video recommendations, we share your country information and third-party website usage data with the third-party video service provider, ACCESS Europe GmbH.
Our media services also support smart peripheral connectivity for a more convenient screen mirroring experience. You can wirelessly mirror content to external devices via in-vehicle WiFi, enhancing your multimedia experience. To enable this function, we may process the vehicle WiFi account, vehicle WiFi password, and WiFi authentication information to ensure secure and stable device connectivity. These credentials cannot be modified and are used solely for authentication purposes in the screen mirroring function, not for any other purpose. We do not store or share your mirrored content, ensuring your privacy and security.
1.2.5.2. App Store
Our App Store provides you with convenient app download and update services to meet your personalized needs. You can easily browse, search, download, or update apps of interest through our app store, enriching the functionality of your vehicle. We need to collect your application download records and smart ID in this case. Application download records help with popular application recommendations, making it easier for you to find and obtain the apps you need quickly. smart ID is used to ensure the security of app downloads and updates, safeguarding your personal data from misuse.
1.3. Other Sources
1.3.1. Payment and Purchase Data
1.3.1.1. Orders
When you purchase smart products or services through smart or its authorized partners, we may collect information about the purchase, such as your personal profile information, order information, contact information, and specific information about the products or services you purchased, to deliver products or provide services to you. We may also process information related to order fulfillment and status to support our services and operational management.
1.3.1.2. Financial
When you make payments for smart products or services, we may collect information about your payment transactions, such as your payment methods, bank account information, credit card information, and billing information, to process your payment.
1.3.2. Roadside Assistance Data
If we directly provide roadside assistance services to you in certain countries/regions, we will collect and disclose your personal data to our contracted roadside service providers as part of the roadside assistance services. This may include your current location, name, mobile phone number, current vehicle issues, license plate number, and VIN.
2. HOW WE USE YOUR DATA
Here are the reasons for collecting your data:
∙ Provide our products and services
∙ Legitimate interests
∙ Consent
∙ Compliance with legal obligations
∙ Public interests
We may use the collected data for various purposes. The following are examples of how we might use your personal data to provide the best quality products and services.
2.1. Provide our Products and Services
2.1.1. Completing your Purchase and Creating your Order
For example, when we use your personal data to:
∙ Establish an account for you
∙ Personalize your account, or
∙ Facilitate the creation of orders when you make a purchase
∙ Process your payment for a product or service
2.1.2. Handling, Assisting, and Providing Relevant Customer Support
For example, when we use your personal data to:
∙ Provide smart App when you download it to your device
∙ Offer additional information such as traffic conditions, maps, etc.
∙ Enable you to create, share, and use content, interact with other users and their content, and provide user support
2.1.3. Managing and Providing the Products and Services you Purchase
For example, when we use your personal data for:
∙ Using physical smart products and digital services
∙ Allowing you to share links to smart content with others
2.1.4. Monitoring the Performance of smart Products and Providing Related Services, Including Over-the-Air (OTA) Updates
For example, when we analyze data to check for safety issues of smart products or services.
2.1.5. Understanding, Categorizing, and Resolving Issues or Concerns with Products or Services
For example, when users contact us for help with urgent issues after their vehicle has been sold.
2.1.6. Enforcing our Terms, Guidelines, or Policies
For example, when we suspend or prohibit your account if we determine that you have violated our terms or guidelines.
2.2. Legitimate Interests
2.2.1. Providing Measurement and Analytics Services
Statistics and analysis of your use of our products or services to help you understand and use our products or services. We may share the statistical and analytical information with the public or third parties to demonstrate our overall service usage trends. Such statistical or analytical information does not include any personally identifiable information and is irreversibly anonymized.
2.2.2. Reviewing, Improving, Promoting, and Developing the Platform
We use the information at our disposal to understand how people use our services, develop, test, and improve our services, including developing and improving our technology. We also use this information to better understand and promote our services.
2.2.3. Sharing your Data with Third Parties
To provide you with a perfect service and facilitate your use of services provided by other third parties.
2.2.4. Marketing Communication
We may send you direct marketing information about platform features and third-party services that we believe may interest you. We may also send you promotions, contests, marketing activities, or event information. We will obtain your consent to send you such messages as required by law.
2.2.5. Establishing, Exercising, or Defending Legal Claims
For example, if we are involved in litigation, we need to provide information related to that legal case to our lawyers.
2.3. Consent
2.3.1. You can voluntarily choose to use certain additional features, in which case we will explicitly seek your consent.
2.4. Compliance with Legal Obligations
2.4.1. Complying with legal obligations that we must adhere to, including obligations under the laws of your country or region.
2.4.2. Complying with requests from law enforcement, courts, or other competent authorities.
2.5. Public Interests
2.5.1. We may use your data when necessary to protect your or others' lives, physical safety, or security. This may include providing information to law enforcement or emergency services in emergency situations to protect health or life.
3. HOW WE SHARE YOUR DATA
If necessary, we will share your data within the smart Ecosystem.
The smart Ecosystem includes smart subsidiaries (entities), third-party vendors, and other partners involved in the daily business of smart.
We will only share your personal data for necessary purposes and within the scope required. For example, if you purchase products or digital services or use after-sales services, your customer data may need to be exchanged among various companies within the smart Ecosystem.
In such cases, these companies must comply with our privacy and data protection requirements and may not use the personal data received from us for any other purposes. During this period, we will not sell your personal data to anyone for any purpose. The following explains with whom smart may share your personal data based on your interactions with us or your purchases.
3.1. Affiliates and Branches
Affiliates and branches represent us to assist, operate, strengthen, and complete specific outsourced services. For example, when you request support, smart entities in different countries may provide the requested services to you through the in-car communication system (e.g., arranging after-sales service appointments).
3.2. Service Providers
Service providers assist us in providing App Stores, voice assistance, SIM cards, vehicle activation, vehicle digital key sharing, video services, navigation, and other services to provide you with more powerful smart functionality.
3.2.1. If you trigger voice assistance services in the vehicle, we may share your voice information with professional service providers to provide you with a smooth and convenient voice assistant function.
3.2.2. When you use vehicle SIM card authentication and registration services, we may share your VIN, address, name, and other information with service providers to provide complete SIM card services.
3.2.3. When you use the smart official website in Applicable Market, we will authorize local service providers to develop and operate the website and share your data with them.
3.2.4. When you use features such as App Store, weather services, OTA services, vehicle digital key sharing, roadside assistance, remote information services, video services, navigation, etc., we may share your data with the respective service providers to provide you with more comprehensive services.
3.3. Third Parties Authorized by you
Third parties authorized by you, mainly providing financial services and vehicle maintenance services.
3.3.1. Financial Institutions
You can authorize financial institutions to enjoy financial services such as purchasing or installment payment discounts.
3.3.2. After-sales and Owner Services
You can contact our authorized service stations for after-sales service or vehicle maintenance.
4. WHERE WE STORE YOUR DATA
Your data may be stored on servers outside your country or region of residence. We maintain primary servers worldwide to provide you with global and continuous services.
5. YOUR RIGHTS AND CHOICES
You have various rights regarding the personal data we hold about you. These rights are outlined below. To exercise any of these rights, please contact us using the contact details provided in this privacy statement.
We will make efforts to process your requests without undue delay and within the deadlines specified by local laws in any case. Please note that upon receiving your request, we may first verify your identity and may ask you to provide necessary information for verification. We may retain records of your communication to assist in resolving any issues you raise.
5.1. Right to Access
You have the right to know what data we have collected from you, for what purposes we process your data, and to whom we will forward your data. You can exercise your right to access by contacting us through the contact details provided in this privacy statement.
5.2. Right to Rectify
You can contact us through the contact details provided in this privacy statement to change or modify your personal data.
5.3. Right to Erasure
If you wish to delete all data, you can access your profile, select the relevant content, and delete it. You can also contact us through the contact details provided in this privacy statement. When you make a request, all data will be deleted, except for data that we have a legal obligation to retain. We will notify you of the deletion results.
We are obliged to immediately delete your personal data in the following cases:
∙ Your personal data is no longer needed for the purposes of collection or other processing.
∙ You withdraw consent, and there is no other legal basis for processing the data.
∙ You object to the processing, and there are no overriding legitimate grounds for continued processing.
∙ Your personal data is processed unlawfully.
∙ It is necessary to delete your personal data to fulfill our legal obligations.
5.4. Right to Restriction of Processing
If you want to restrict the processing of your data, you can contact us through the contact details provided in this privacy statement. You have the right to request the restriction of our data processing under the following conditions:
∙ You question the accuracy of personal data.
∙ The processing of data is unlawful, but you oppose the deletion of personal data and request restriction of its use.
∙ We no longer need personal data for processing purposes, but you need the data to establish, exercise, or defend legal claims.
∙ You object to processing, and we cannot demonstrate overriding legitimate grounds for continued processing.
5.5. Right to Data Portability
If you wish, you have the right to transfer your personal data between service providers. In practice, this means you can transfer the details we hold about you to another third party. For your convenience, we will provide your data to you in a commonly used machine-readable format to facilitate the transfer.
5.6. Right to Object
You have the right to object to the processing of your personal data in certain situations (e.g., if we process your data for advertising purposes). If you wish to object to the processing of your personal data, you can contact us through the contact details provided in this privacy statement.
5.7. Right to Withdraw Consent
You can withdraw your consent at any time, and withdrawing consent does not affect the processing of your data before the withdrawal. When you wish to exercise any of the above rights, you can adjust relevant controls on smart or contact us through the contact details provided in this privacy statement.
5.8. Right to Complain
If you believe that the processing of your personal data violates legal regulations, you have the right to complain to the local supervisory authority for data protection.
5.9. Marketing Preferences
You can contact us through the contact details provided in this privacy statement to unsubscribe from our promotional messages. Please note that even if you choose not to receive our promotional messages, you will still receive our administrative information.
6. THE SECURITY OF YOUR DATA
We aim to provide reasonable and appropriate managerial, technical, and organizational security measures to protect your personal data from temporary or permanent loss, destruction, unauthorized or illegal access, alteration, use, or disclosure risks. We require our suppliers to apply similar protective measures when accessing or using the personal data we share with them. No technology, data transmission, or system can guarantee 100% security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that any smart data has been compromised), please notify us immediately following the instructions in the "CONTACT US" section.
7. HOW LONG WE KEEP YOUR DATA
We only store your personal data for the time necessary for the relevant purposes. If data is processed for multiple purposes, once the final specified purpose is completed, the data will be automatically deleted or stored in a form that cannot be directly traced back to you. However, personal data must be retained for a longer period as required by local laws, in which case, personal data must continue to be retained within the time frame specified by law.
8. DATA TRANSFER TO THIRD COUNTRIES
If necessary, we may transfer your personal data between smart's location and subsidiaries and affiliates in other countries. We may also transfer your personal data to our third-party service providers, which may be located in countries different from yours.
We conduct information transfers to provide you with necessary and efficient services and to protect information against failures or other issues. We will handle your personal data in a manner consistent with the commitments of this statement and in compliance with legal requirements, regardless of where we transfer it.
Whenever smart transfers personal data to a country or region outside of its origin, we will do so in accordance with the applicable legal provisions.
9. CHILDREN
Our products and services are not targeted at individuals under the age of 18. In some cases, due to local regulatory requirements, this age limit may be higher; please refer to your local supplementary terms for more information. We do not intentionally collect personal data from individuals under the age of 18. If you have reason to believe that an individual under the age of 18 has provided personal data to us through any means, you can contact us through the contact details provided in this privacy statement. We will investigate any such notifications and, where appropriate, delete the personal data.
10. PRIVACY STATEMENT UPDATE
To better serve you, we may update this statement periodically based on product and service updates and relevant legal requirements. You may need to read and accept any revised statement to continue using smart products and services.
We will present the updated content prominently on the page, through pop-ups, message notifications, website announcements, or other appropriate forms that comply with legal requirements and are convenient for you to be informed. We will provide you with the option to voluntarily agree to the updated statement, and in such cases, it is essential for you to thoroughly read and understand the updated or modified privacy statement.
Please check this statement regularly for any updates. If you continue to use smart products and services, you will be considered as consenting to the updated version of this privacy statement.
11. CONTACT US
You can contact us by sending an email to smartcareglobal@smart.com.
12. SUPPLEMENTAL TERMS
12.1. Hong Kong Special Administrative Region
If you are using our services in the Hong Kong Special Administrative Region, the following additional terms apply.
As a data subject in the Hong Kong SAR, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations).
You have the right to make a subject access request (to receive a copy of the data we process about you). You may also exercise the right to correct data and the right to stop the use of your personal data for direct marketing purposes. We may charge a fee for complying with data access requests.
If you choose to receive our marketing communications, we may use your (or relevant individuals') personal data to send you information about our latest products and services. We may use email and/or Short Message Service (SMS) for this purpose. For this, we will process information such as your (or relevant individuals') name, email address, gender, and address. We will retain your (or relevant individuals') personal data until you no longer wish to receive our information. You can contact us or use the unsubscribe option included in each email and/or SMS to decide at any time not to receive our communications or updates.
12.2. Singapore
If you are using our services in Singapore, the following additional terms apply.
As a data subject in Singapore, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations). You may, with reasonable notice, withdraw your consent to our use and disclosure of data. Upon withdrawal of consent, we will promptly cease using your personal data, which may result in you being unable to access certain features.
Without your explicit consent, we will not sell or rent your personal data to third parties for marketing purposes. If you do not wish to receive our marketing communications or participate in our advertising customization programs, you can set your preferences in the settings provided or contact us.
12.3. Macau Special Administrative Region
If you are using our services in the Macau Special Administrative Region, the following additional terms apply.
As a data subject in the Macau Special Administrative Region, you have the legal right over your personal data held by us (to the extent permitted by applicable laws and regulations).
You have the right to make access requests, obtain copies of the data we process about you, request data correction, and have the right to object to the use of your personal data for marketing purposes. We may charge fees for complying with data access requests.
12.4. Israel
If you are using our services in Israel, the following additional terms apply.
As a data subject in Israel, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations).
Under the Privacy Protection Law, you have the right to access, correct, or delete your data. If you wish to correct or update your personal data, or request access or deletion of your personal data, you can contact us through the contact details provided in this privacy statement. If you request changes or deletion of your personal data, please note that we may still need to retain certain information for record-keeping purposes and/or to complete any transactions initiated before such changes or deletion were requested (e.g., if you made a purchase or participated in a promotional activity, you may not be able to change or delete the personal data provided until after completing such purchase or promotional activity).
12.5. Australia
If you are using our services in Australia, the following additional terms apply.
As a data subject in Australia, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations). If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide or by contacting our customer service.
Certain entities within our corporate group located outside of Australia are granted limited remote access to your information to perform certain functions. We will take reasonable measures to ensure that these entities protect your personal data in accordance with applicable privacy regulations.
12.6. Chile
If you are using our services in Chile, the following additional terms apply.
As a data subject in Chile, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations).
We take reasonable measures to ensure that your personal data is adequately protected, including ensuring that entities accessing data from outside Chile provide equivalent protection measures as required by Chilean law. If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide or by contacting our customer service.
12.7. Malaysia
If you use our services in Malaysia, the following additional terms shall apply.
Our server is in Singapore. As a data subject in Malaysia, you consent to our transfer of your data outside your country.
We will only transfer your personal data outside Malaysia in accordance with the Malaysian personal data protection laws and where required, will ensure that the recipient processes personal data not in contravention of the Malaysian personal data protection laws.
You have legal rights regarding the personal data we hold (to the extent permitted by applicable laws and regulations). If you do not wish to receive our marketing communications or advertisements, you may opt-out through the settings we provide or by contacting our customer service.
This Privacy Statement is issued in both English and Malay languages. In the event of any inconsistencies between the English version and the Malay version, the English version shall prevail.
12.8. New Zealand
If you are using our services in New Zealand, the following additional terms apply.
As a data subject in New Zealand, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations). Without your consent, we will not send you messages for direct marketing. If you do not wish to receive our marketing communications or participate in our advertising customization programs, you can choose to opt out by using the settings provided, or by contacting us directly.
You can make a complaint under the Privacy Act 2020 to the Office of the Privacy Commissioner of New Zealand.
12.9. Colombia
If you are using our services in Colombia, the following additional terms apply.
As a data subject in Colombia, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations).You may exercise your right to access, rectify, update, delete your personal data, or other data subject rights granted by applicable laws and regulations, by contacting us using the contact details provided in this Privacy Statement. We will respond to your request in compliance with applicable laws and regulations.
If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide or by contacting our customer service.
12.10. Uruguay
If you are using our services in Uruguay, the following additional terms apply.
As a data subject in Uruguay, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations). You may exercise your right to access, rectify, update, supplement or delete your personal data, object to its processing or other data subject rights granted by applicable laws and regulations, by contacting us using the contact details provided in this Privacy Statement. We will respond to your request in compliance with applicable laws and regulations.
If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide or by contacting our customer service.
12.11. Ecuador
If you are using our services in Ecuador, the following additional terms apply.
As a data subject in Ecuador, you have legal rights over your personal data held by us (to the extent permitted by applicable laws and regulations). You may exercise your right to access, rectify, update, delete your personal data, restrict or object to processing your personal data, transfer your personal data to third parties or other data subject rights granted by applicable laws and regulations, by contacting us using the contact details provided in this Privacy Statement. We will respond to your request in compliance with applicable laws and regulations. If you are dissatisfied with the processing of your personal data or the response you have received when exercising your rights, you have the right to lodge a complaint with the Superintendence of Data Protection.
If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide or by contacting our customer service.
12.12. Argentina
If you are using our services in Argentina, the following additional terms apply.
The collection and processing of personal data in Argentina are carried out in accordance with the Personal Data Protection Law No. 25,326, its Regulatory Decree No. 1558/2001, and other applicable complementary regulations (collectively, the “Applicable Argentine Personal Data Protection Regulations”).
To the extent required by the Applicable Argentine Personal Data Protection Regulations, we will register the relevant databases or processing activities involving personal data in Argentina with the RNBDP (“Registro Nacional de Bases de Datos Personales”) maintained by the AAIP (“Agencia de Acceso a la Información Pública”), and will update such registration as required by the Applicable Argentine Personal Data Protection Regulations.
As a data subject in Argentina, you have legal rights over your personal data held by us (to the extent permitted by the Applicable Argentine Personal Data Protection Regulations).You may exercise your right to access, rectify, update, delete your personal data or other data subject rights granted by the Applicable Argentine Personal Data Protection Regulations by contacting us using the contact details provided in this Privacy Statement. We will respond to your request in compliance with the Applicable Argentine Personal Data Protection Regulations.
12.13. Costa Rica
If you are using our services in Costa Rica, the following additional terms apply.
The collection and processing of personal data in Costa Rica are carried out in accordance with Law No. 8968, its implementing regulation, Executive Decree No. 37554-JP, and other applicable complementary regulations (collectively, the “Applicable Costa Rican Personal Data Protection Regulations”).
As a data subject in Costa Rica, you have legal rights over your personal data held by us (to the extent permitted by the Applicable Costa Rican Personal Data Protection Regulations). You may exercise your rights to access, rectify your personal data, revoke consent where the processing is based on consent or other data subject rights granted by the Applicable Costa Rican Personal Data Protection Regulations by contacting us using the contact details provided in this Privacy Statement. We will respond to your request in accordance with the Applicable Costa Rican Personal Data Protection Regulations.
12.14. Thailand
If you are using our Services in Thailand, the following additional terms apply.
The collection, use, disclosure and processing of personal data in Thailand are carried out in accordance with the Personal Data Protection Act 2019, its subordinate regulations, notifications, guidelines and other applicable complementary regulations, as amended from time to time (collectively the “Applicable Thai Personal Data Protection Laws”).
We will collect, use, disclose, and process your personal data only where we have a lawful basis to do so under the Applicable Thai Personal Data Protection Laws including where it is necessary for the performance of a contract, compliance with legal obligations, our legitimate interests, the establishment, compliance, exercise or defence of legal claims or where you have given your consent. Where consent is required, you may withdraw your consent at any time, subject to the conditions and limitations under the Applicable Thai Personal Data Protection Laws.
If we collect, use, disclose or process sensitive personal data, we will do so only where permitted by law, where we have obtained your explicit consent or where another lawful basis under the Applicable Thai Personal Data Protection Laws applies.
Where your personal data is transferred outside Thailand, we will ensure that such transfer is carried out in accordance with the Applicable Thai Personal Data Protection Laws, including by implementing appropriate safeguards or relying on another lawful basis or exemption permitted under such laws.
As a data subject in Thailand, you have legal rights over your personal data held by us, to the extent permitted by the Applicable Thai Personal Data Protection Laws. These rights may include the right to access, obtain a copy of, rectify, update, delete, destroy or anonymise, restrict the use of, object to the collection, use, disclosure or processing of, or request portability of your personal data. You may also withdraw your consent where the processing is based on consent, lodge a complaint with the Office of the Personal Data Protection Committee, or exercise any other data subject rights granted by the Applicable Thai Personal Data Protection Laws.
You may exercise your rights by contacting us using the contact details provided in this Privacy Statement. We will consider and respond to your request within the period prescribed by the Applicable Thai Personal Data Protection Laws. We may refuse to comply with your request where we are permitted or required to do so under applicable law.
If you do not wish to receive our marketing communications or advertisements, you may opt out through the settings options we provide, by using the unsubscribe mechanism included in our communications or by contacting our customer service.
Last Update: 27th May 2026
Version：PV-2026-1