Privacy Policy
This Privacy Policy (“Privacy Policy” or “Policy”) explains the manner in which Smartian Private Limited (“we”, “us”, or “our”) may collect, use, disclose and/or otherwise process personal data of users who access and use the Platform and/or Services (as defined in our Terms of Use) (“Users”, “you” or “your”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose and/or process personal data for our purposes.

“personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. Some examples of personal data which we may collect include your name, identification number and contact details.

Please read this Policy carefully before using the Platform and/or Services. By accessing and using the Platform and/or Services, you agree that you have read and have understood the requirements and practices set out in this Policy, and consent to our collection, use, disclosure and/or processing of your personal data as described in this Policy. If you do not consent to our collection, use, disclosure and/or processing of your personal data as described in this Policy, please do not access or use the Platform and/or Services.

We reserve the right to change or modify this Policy at any time without prior notice. Such changes or modifications to this Policy will be effective once they are posted on the Platform. You are responsible for regularly reviewing this Policy. Your continued access and use of the Platform and/or the Services after such changes or modifications have been made constitutes your acknowledgment and acceptance of such changes or modifications to this Policy

This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure and/or processing of your personal data by us.

Types of personal data
The personal data that we may collect includes (but is not limited to):
  1. Name;
  2. Date of birth;
  3. Phone number;
  4. Email address;
  5. Billing and/or delivery address;
  6. Location data;
  7. Bank account details, credit card and/or debit card details and such other payment details;
  8. Data associated with the devices used to access the Platform and/or Services including IP address, MAC address, browser type, IMEI number, cookies, etc;
  9. Usage and transaction data including searches, orders, payments and interaction with advertisements and such other content made available on the Platform and/or Services;
  10. Marketing and communications data including preferences in receiving marketing collateral from us and third parties, communication preferences and history of communications with us, our service providers, and other third parties;
  11. Information we may request from time to time for our due diligence, identity verification and/or fraud prevention;
  12. Such other information when you register for an account with us and/or access or use the Platform and/or Services.
Collection of personal data
We may collect your personal data in the following circumstances:
  1. when you register for an account with us;
  2. when you access and use our Platform and/or Services;
  3. when you conduct a transaction on the Platform and/or via the Services;
  4. when you use any payment related functions made available on the Platform;
  5. when you interact with us, whether online or offline, including to seek assistance from our customer service agents or to provide feedback or complaints;
  6. when you subscribe to our marketing collaterals;
  7. when your grant permission on your device to share information with the Platform;
  8. when you participate in any campaigns, promotions and/or surveys on thePlatform; and
  9. when you submit your personal data to us for any reason.
Please note that the above are just some circumstances in which we may collect your personal data and it is not an exhaustive list.
You shall not submit any information which is inaccurate or misleading, and you shall inform us of any inaccuracies or changes to such information. We reserve the right to require such documentation to verify the information provided by you.
Use of personal data
We may use your personal data for any or all of the following purposes:
  1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
  2. verifying your identity and conducting due diligence checks;
  3. facilitating the creation, administration, access, use and security of your account;
  4. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
  5. managing your relationship with us including sending administrative information in connection with the Platform and/or Services;
  6. processing payment or credit transactions;
  7. conducting analysis, research and development activities to understand how you utilise the Platform and/or Services, to recommend goods and/or services that may interest you, to improve the Platform and/or Services and/or to enhance user experience
  8. sending marketing and advertising collaterals relating to the Platform and/or Services and/or goods and/or services made available on the Platform by third parties. You may unsubscribe from receiving such marketing and advertising collaterals at any time by using the unsubscribe function within the electronic marketing material;
  9. preparing and maintaining records for internal and statutory reporting and/or record-keeping requirements;
  10. negotiating a business transaction including, but not limited to, any financing, merger, acquisition or liquidation involving us;
  11. managing our business operations including, but not limited to, our technology infrastructure;
  12. preventing, detecting, investigating fraud, misconduct, unauthorised or illicit activities and/or violations (actual or suspected) of our of Use or any other matter relating to your relationship with us
  13. seeking professional advice;
  14. enforcing our Terms of Use and/or any obligations owed to us;
  15. protecting our rights and property, or the safety, rights and property of other users, partners and/or third parties;
  16. responding to any claims (threatened or actual) against us;
  17. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law and investigations conducted by any governmental and/or regulatory authority;
  18. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
  19. any other purposes which we notify you of at the time of obtaining your consent.
Disclosure of personal data
We may use your personal data for any or all of the following purposes:
  1. where such disclosure is required for performing obligations in the course of or in connection with our provision the goods and/or services requested by you;
  2. where we are required to do so by law, to comply with any legal process, pursuant to any court order or a lawful request by any regulatory or governmental authority having jurisdiction over us, or where we believe, disclosure is required to prevent the commission of any fraud or crime, to enforce our Terms of Use, to respond to any claims (threatened or actual) against us, to protect our rights and property, and/or to protect the safety, rights and property any other person;
  3. to your employer to allow them to administer your account with us and to monitor your use of the Platform and/or Services;
  4. to third-party service providers to verify your identity and to provide you with the good and/or services you have purchased;
  5. to our employees, third-party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
If you provide us with the personal data of any third party, you represent, warrant and undertake to us that you have obtained the necessary consents and permissions from that third party to share and transfer that third party's personal data to us, and for us to collect, store, use, disclose and/or otherwise process that personal data in accordance with this Policy.
You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data by submitting your request via email to our Data Protection Officer at []. However, should you choose to do so, we may not be able to continue providing our goods and/or services to you, or perform any contract we may have with you, and may need to terminate your relationship with us or any contract we have with you, and we shall not be liable to you in any manner whatsoever for such termination.
Upon receipt of your email to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
You are responsible for ensuring that the personal data that you provide us with and/or that is in our possession is accurate, complete and up to date. If there are any changes to your personal data, you may update your personal data by accessing your account on the Platform.
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct any personal data which we hold about you, you may email our Data Protection Officer at [].
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request and will process your request after you have paid such fee.
We reserve the right to refuse an access request and/or a correction request in accordance with the provisions of the applicable laws.
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate administrative, physical and technical measures such as access controls (such as good password practices, need-to-basis for data disclosure, etc.), and encryption of data.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
We may transfer, store and/or otherwise process your personal data outside of Singapore. If we do so, we will ensure that your personal data receives a standard of protection that is at least comparable to that provided under the Personal Data Protection Act 2012 of Singapore.
Cookies, web beacons and other similar technologies may be utilised by us and/or our authorised service providers with regard to your access and use of the Platform and/or Services. For example, when you visit the Platform information such as your IP address and browser type etc will be recorded on our and/or third-party servers.
The data collected is used, among other things, to analyse and evaluate User experience and improve the Platform and/or Services, tailor content to your preferences and provide you with relevant advertisements/promotions.
You may refuse and delete cookies via your browser and/or mobile settings. However, should you choose to do so, please note that certain functionalities available on the Platform and/or Services may be affected.
The Platform may contain links to other websites operated by other parties such as our partners, affiliates, merchants or payment gateways (“3rd Party Websites”). These links are provided for your convenience only.
We have no control over the privacy practices and security arrangements of 3rd Party Websites, and therefore, we shall not be responsible or liable for the same. You should read the applicable privacy policies of 3rd Party Websites to understand how such websites collect, use, disclose and/or otherwise process your personal data.
You may email our Data Protection Officer at [] if you have any enquiries or feedback on this Policy, or if you wish to make any request.
Last updated:
5 April 2022
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