PRIVACY STATEMENT
Our Privacy Commitment
Smart Communications, Inc. (“SMART”) respects our customers’ fundamental right to privacy, and we commit to take
great care in safeguarding your personal data. SMART has developed a privacy statement that aims to ensure that we
adopt and observe appropriate standards for personal data protection in compliance with applicable privacy laws and
regulations.
While this privacy statement sets out the general principles that govern the collection, use, and disclosure of our
customers’ personal data, we have also developed this privacy statement to inform you more specifically about our
privacy practices.
Why we collect your personal data
Throughout your use of our services, we collect and maintain some information about you. We do so only for the
purposes and legal bases described below.
- We process your personal data to perform our obligations under contract with you.
- To create and provision your prepaid subscription. We collect information about your
use of our prepaid
services to charge fees from your airtime load top-ups for the products you obtain from us. We also use
this usage information to verify your ownership of your prepaid account during after-sales care
transactions through our hotline or stores.
We use a combination of manual, partly automated, and automated processes to deliver our services
efficiently. Human intervention is inserted at key stages to ensure proper system functioning.
- We process your personal data to comply with legal requirements.
- To assist public authorities. We produce statistical insights from your use of our
network and facilities to assist public authorities in planning for healthcare, disaster management, and
other similar initiatives for public benefit. Whenever possible, we aggregate and anonymize this
information to ensure individual identities are protected and not disclosed.
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To comply with legal requirements. We may process or disclose personal data as
necessary to comply with applicable legal and regulatory requirements.
For example, we adhere to Republic Act No. 11934, also known as the Subscriber Identity Module (“SIM”)
Registration Act. We utilize optical character recognition (“OCR”) technology to validate the proof of
identification (“POID”) submitted during SIM registration. OCR facilitates facial recognition and
automatically transfers the details from the POID to SMART’s customer application database. This use of
OCR technology ensures the prevention of identity impersonation. For more information about SIM
Registration, please visit http://tntph.com/Pages/sim-reg.
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We process your personal data based on our legitimate interest to function effectively as a business,
except when your fundamental rights and freedoms override our interests. Such interests, include, among
others:
- To manage and nurture our relationship with you as you use our products and services.
We collect and process your personal data in connection with your use of our services to manage your
prepaid account, provide aftersales customer care, and address your service-related requests and
concerns. Additionally, we process your personal data to verify your identity and ownership of your
prepaid SIM Card when you contact us through our hotline or visit our stores for after-sales
transactions. We may also include your personal contact details in an internal directory listing to
facilitate effective communication and assistance.
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To continuously improve our business and operations. We analyze your usage of our
network and service to monitor and manage the quality and security of the network, train our staff, and
plan for future growth.
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To continuously improve our products and services. We collect, use, process, and
analyze how you use our products and services to understand how to improve them and identify relevant
products and offers. This analysis includes maintaining a record of the products and services you use
(such as the volume and frequency of your SMS, voice, and data services) and your historical locational
information (based on the locations where you have used the products and services). We also analyze
other activities, such as your participation in market research initiatives, visits and transactions in
SMART stores, and visits and usage of any of TNT’s websites and mobile apps such as https://tntph.com.
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To manage the security of our business operations. We process your personal data to
conduct IT security operations, manage our assets, ensure fair use of our products and services, and
support business continuity, disaster recovery, and audit purposes.
In pursuit of these interests, SMART’s activities include monitoring its network with automated tools
such as firewalls, capable of comparing suspicious data transmissions with known threats to deter
cyber-attacks and detect and prevent fraudulent schemes, including smishing and identity theft, against
SMART and you. During such monitoring, SMART may analyze traffic data and, if necessary, details
relating to your identity, contact information, service usage, device information, and communication
content. Should you commit any cyber-attack, fraud, or similar schemes, SMART may block your access to
the Service without prior notice.
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To send you information about our products and offers, including those of our subsidiary and
affiliate companies. We analyze your usage of our SMS, voice, and data services to:
- understand the market’s needs, wants and trends;
- recommend suitable products and services and send you such information through SMS, e-mail, and
voice calls. Our advisories may include location-based offers that are exclusively available in
your area; and
- determine the effectiveness of our marketing efforts and initiatives.
If you prefer not to receive these messages from SMART, you can manage your communication preferences at
https://tntph.com/privacy.
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We process your personal data for additional purposes and activities that are completely optional. We
will only perform these activities with your specific consent. If you agree to any of these additional
activities, you can withdraw your consent at any time by visiting https://tntph.com/privacy.
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Create a personal profile about you. We process your personal and sensitive personal
information, analyzing it alongside your usage of our products and services (including data regarding
the specific websites and applications you visit), to gain a comprehensive understanding of and
anticipate your personal needs and interests. Additionally, we may collect personal information about
you from third-party sources such as SMART’s subsidiaries, affiliates, and business partners, to whom
you have provided consent to share your information.
This enhanced profile is created to better understand your preferences, allowing us to deliver more
targeted and personalized product recommendations, special offers, and promotions directly to you.
- Send you information about SMART and TNT products and offers through third-party messaging
applications. With your consent, we may send you product information, offers, and promos via
Viber, Google, Facebook Messenger, and other third-party messaging technologies.
- Send you advertisements from third parties. We process your usage information, personal
profile, and contact details to send you customized offers and promotions from our third-party business
partners for the promotion of their own products and services.
Your personal data is not shared
with these third parties. You only consent to SMART sending you direct marketing offers from our trusted
partners.
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Share your personal data with third parties. We may disclose your personal data to
SMART’s subsidiary and affiliate companies, as well as third-party business partners, for their
independent business purposes.
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Data and Profile Sharing with Third Parties
We may share your usage profile (how you use our network, products, and services, including
purchase history) and personal profiles (your preferences and interests based on usage data) for
the independent business interests of our subsidiaries, affiliates, and trusted business
partners. You can find a list of companies to whom we may disclose this information at https://tntph.com/privacy-policy#affiliates.
What personal data do we collect?
Whenever you transact or otherwise interact with Smart, we may collect the following personal data about you:
We collect the following information for SIM Registration:
Complete Name, Mobile Number, Gender, Residential Address, Birthdate, Selfie, and photo of Government-issued ID
For Foreign Nationals holding a Non-Tourist Visa:
- Passport Number
- Photo of the Passport
- Proof of Address in the Philippines
- Alien Certificate of Registration Identification Card (ACRI Card) issued by the Bureau of Immigration (BI)
- Alien Employment Permit issued by the Department of Labor and Employment (DOLE) or School Registration and ID
for students
- For Persons of Concerns (POCs), the type of travel or admission document validly issued by the Department of
Justice.
For Foreign Nationals holding a Non-Tourist Visa:
- Passport Number
- Photo of the Passport
- Proof of Address in the Philippines
- Return Ticket to own country of the tourist, or any other ticket showing the date and time of departure from the
Philippines.
If you are a TNT Retailer:
- Mobile Number
- Retailer/Store Type
- Complete Name
- Birthdate
- Store Address
If you are a Self-Help App User
For the GigaLife App:
- Mobile Number
- Alternate mobile number (as alternate contact for Broadband accounts)
For MySmart:
- Complete Name
- Mobile Number
- Billing Address
- Delivery Address
- Email Address
For Giga Arena:
- Mobile Number
- Username
- Birthdate (for age validation)
- Region of Location
For Smart Livestream:
If you are registering to a Marketing Promo or Event
- Mobile Number
- Complete Name
- Residential Address
Note: Depending on the nature of the promo or event, we may collect other personal data. Specific
details of the data collection will be set out in the Privacy Notice of said promo or event.
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If you are applying for a job in Smart
Please refer to the Privacy Notice for Smart Applicants here.
If you are a contractor of Smart
- Complete Name
- Contact Number
- Name and Address of Employer
If you are a visitor to any of Smart’s offices
- Complete Name
- Valid ID
- Name and Address of Employer
How we collect your personal data
We collect your personal data from several resources.
Information you share with us
Most of the personal data we retain are information you have shared with us. You provide us with personal data when
you:
- Apply for our services by filling out application forms, subscription agreements, and other similar or related
documents through any of our available channels (online, in our stores, or through our sales representatives);
- Get in touch with us to ask about something, file a complaint or request for service;
- Take part in our research and surveys; and/or
Information we collect during our relationship with you
We also collect information as you use our products and services, like when you:
- Use our network, facilities and services - whether it is Mobile, Fixed, Home, or any of our other products,
services, and channels;
- Pay your bills or purchase add-on products and services;
- Use our apps, websites, and self-service channels and portals;
- Join our promos, prize raffles, or rewards & loyalty programs;
- Participate in our market research activities; and
- Visit and transact in our stores.
Information we collect from other sources
We may also collect your personal data, from our subsidiaries, affiliates, and trusted business partners, to whom you
have also given your consent for them to share your information with us.
How we store your personal data
We store your personal data using secure systems and processes designed to protect it from unauthorized access,
alteration, or loss. Depending on how you interact with us, your data may be stored in physical formats (such as
signed forms or printed documents) or electronically (such as in databases, cloud platforms, or secure servers).
When we disclose your personal data
There are a variety of circumstances where we may need to share some of the information that you have provided to us.
In these cases, we ensure that your personal data is disclosed on a confidential basis, through secure channels, and
only in compliance with applicable privacy laws and regulations.
We will never share, rent, or sell your personal data to third parties outside of SMART except in special
circumstances where you may have given your consent for, and as described in this statement.
In some instances, we may be required to disclose your personal data to our agents, subsidiaries, affiliates,
business partners and other third-party agencies and service providers as part of our regular business operations
and for the provision of our products and services. This means we might share your information with:
- Our service providers, contractors, and professional advisers who help us provide our products and
services. Under an obligation of confidentiality, we allow access to your personal data to authorized
third-party service providers / vendors / suppliers / contractors / subcontractors / consultants / professional
advisers (“Third-Parties”) who provide outsourced functions within or outside the Philippines to help us
facilitate our products and/or services, to provide the service on our behalf, or to assist us in analyzing how
our service is used. These include, among others:
- Cloud storage facilities/systems to meet our storage management requirements;
- Credit Investigation;
- Collections;
- Marketing;
- Websites and Mobile applications; and
- Other outsourced functions as approved by SMART.
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Our subsidiaries and affiliates with whom you also have an account with. If you are, become, or
apply to become, a customer of our subsidiaries and affiliates, SMART and our subsidiary/ies and/or affiliate/s
concerned have the option, but not the obligation, to rely upon, use, and share your relevant personal
information for any of the following purposes:
- To facilitate your account opening or other transaction with the concerned subsidiary/ies or
affiliate/s;
- To validate, consolidate, or update your account information;
- For research purposes or to design related products or services for your benefit and use; and
- To comply with a legal obligation to which SMART or the concerned subsidiary/ies or affiliate/s is
subject.
We provide these Third-Parties access to your personal data for the effective performance of their assigned
tasks on our behalf, based on our instructions and in compliance with our Privacy Notice and other appropriate
confidentiality obligations and security measures.
SMART remains responsible for the personal data disclosed to such Third-Parties. Thus, we ensure that such
Third-Parties are contractually obligated to comply with the requirements of Privacy Laws and shall process your
personal data strictly in accordance with the purposes enumerated above.
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Other companies to whom you have given us consent to share your information with. For instance,
when you register for products and services provided by other companies, they may request information from us to
verify your identity.
In all of the above cases, we ensure that your personal data is disclosed on a confidential basis, through secure
channels, and only in compliance with applicable privacy laws and regulations. We do not share, rent, or sell your
personal data to third parties outside of SMART, except in special circumstances where you may have given your
consent and as described in this Notice. For a list of our partners, please visit https://tntph.com/privacy-policy#affiliates.
When we disclose your personal data with the Government and other duly authorized entities, as may be required by law
or legal process, we ensure that your personal data is protected and shared according to the rules and regulations
and Government guidelines, where such is available.
How we protect your personal data
The integrity, confidentiality, and security of your information are important to us. That’s why we strictly enforce
our privacy statement within SMART and have implemented technical, organizational, and physical security measures
that are designed to protect your information from unauthorized or fraudulent access, alteration, disclosure,
misuse, and other unlawful activities. These are also designed to protect your information from other natural and
human dangers.
We also put in effect the following safeguards:
- We keep and protect your information using a secured server behind a firewall, encryption and security
controls;
- We keep your information only for as long as necessary for us to (a) provide the products and services that you
avail from us, (b) for our legitimate business purposes, (c) to comply with pertinent laws, and (d) for special
cases that will require the exercise or defense of legal claims and for a maximum retention period of twelve
(12) years from your service's permanent deactivation.
- We restrict access to your information only to qualified and authorized personnel who are trained to handle your
information with strict confidentiality;
- Our third-party partners are contractually bound to protect your data and handle it with strict
confidentiality;
- We undergo regular audits and rigorous testing of our infrastructure’s security protocols to ensure your data is
always protected;
- We promptly notify you and the competent data protection authority, when sensitive personal data that may, under
the circumstances, be used to enable identity fraud are reasonably believed to have been acquired by an
unauthorized person;
- We let you update your information securely to keep our records accurate.
- When your personal data is no longer needed, we securely dispose of them manually (such as shredding of printed
documents, use of locked disposal bins for confidential documents pending destruction, secure handover to
accredited document destruction vendors with certification of disposal) or electronically (such as, Use of data
wiping software, secure deletion tools, physical destruction of storage media, and use of secure file deletion
protocols for cloud-based storage) as may be applicable.
What your choices are
You are afforded certain rights in relation to your personal data under applicable data privacy laws and
regulations.
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable
law) to:
- Request access to the personal data we process about you: this right entitles you to know
whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal
data.
- Request a rectification of your personal data: this right entitles you to have your personal
data corrected if it is outdated, inaccurate, or incomplete.
- Request the erasure of your personal data: this right entitles you to request the erasure of
your personal data, such as in cases where your personal data is no longer necessary to achieve the legitimate
business purpose of its use or processing.
- Request the restriction of the processing of your personal data: this right entitles you to
request that we only process your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy of
personal data that you have provided to us (in a structured, commonly used, and machine-readable format). This
includes requests for us to transmit a copy of such personal data to another company on your behalf.
You moreover have a right to object to the processing of your personal data, such as in cases when we process your
personal data for purposes related to direct marketing.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such
consent at any time by contacting our Data Privacy Officer through the contact details provided below, or by
accessing https://tntph.com/privacy. Please note that this will not affect
the lawfulness of the processing that was carried out before you withdrew your consent or SMART’s right to continue
parts of the processing based on other legal bases than your consent. If, however, we have not provided you with
another legal basis justifying the processing of your personal data in this privacy statement, we will stop the
processing and delete your personal data.
To exercise these rights, you may get in touch with our Data Privacy Officer through the contact details provided
below. In some instances, we may request for supporting documents or proof before we effect any requested changes to
your personal data.
Smart Communications Inc.
Data Privacy Office
Makati General Office (MGO) Building
Dela Rosa St. corner Legaspi St., Legaspi Village,
Makati City, Metro Manila, Philippines
Email: dpo@smart.com.ph
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have
been violated and—depending on the circumstances—you may be entitled to be indemnified for damages, we encourage you
to contact us first to resolve your complaint. You have the right at all times to register a complaint directly with
the National Privacy Commission or otherwise make a claim against SMART with a competent court.
Changes to our privacy statement
From time to time, we may update our privacy statement and practices to comply with changes in applicable laws, to
comply with government and regulatory requirements, to adapt to new technologies and protocols, to align with
industry best practices, and for business purposes.
You will always be provided notice if these changes are significant and, if we are required by law, we will ensure to
obtain your updated consent.
This Privacy Statement is effective September 18, 2025.