PRIVACY STATEMENT

Our Privacy Commitment

Smart Communications, Inc. respects our customers’ fundamental right to privacy, and we commit to take great care in safeguarding your personal data. Smart Communications, Inc. has developed a Privacy Policy that aims to ensure that we adopt and observe appropriate standards for personal data protection in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 and its implementing rules and regulations.  

While our Privacy Policy sets out the general principles that govern the collection, use, and disclosure of our customers’ personal information, we have also developed this Privacy Commitment to inform you more specifically about our privacy practices.

 
Why we collect your personal information  
As customers of Smart Communications, Inc., we collect and maintain some basic information about you. We do so only for the following purposes:

• To create and nurture a relationship with you, so that we can continuously provide you with our services. For example, when you apply for any of our services, we collect personal information about you that will allow us to validate your identity and credit history  for purposes of billing and collection of fees for the products and services  that you avail from us. 

• To improve our products and services. We collect, use, process, and analyze how you use our products and services so that we can understand how to improve them for your benefit.

• To understand your needs and preferences so that we can serve you better. Maintaining a record of the products and services that you avail from us allows us to gain a better insight of the kinds of offers that would be relevant to your preferences. From time to time, we may send you product recommendations and special offers that we think will interest you.

• To continuously improve our business and operations. For example, we analyze customer usage of our network and facilities to help us manage your account, provide customer care activities, monitor the quality and security of the network, train our staff, and plan for future growth. 

• To assist the Government. We generate statistical insights based on your usage of our network and facilities to assist the Government in planning for healthcare, disaster management, and other similar initiatives.  When we can, we aggregate and anonymize this information such that you are never identified as an individual. [Aggregating simply means presenting information in segments or categories like age groups; anonymizing means removing personally identifiable information from the data]. 

• To comply with the Credit Information System Act. We run credit scoring programs and initiatives, including but not limited to, providing information to the Credit Information Corporation in accordance to Republic Act No. 9501. 

• To meet legal and regulatory requirements. We perform such other processing or disclosure that may be required to comply with pertinent laws, rules, or regulations.
 

 
Where we get these information
There are several ways we collect information about you.
 
Information that you personally give us.   
Most of the personal information we have are those that you have given us yourself. You provide us personal information 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; 
• Become our Partner, Vendor, Contractor or Supplier; and/or
• When you apply for job with us. 
 
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, Enterprise, 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. 
 
Information we collect from other sources 
We also collect personal information about you through other activities such as our market research initiatives, when you visit and transact in our stores, when you visit and use our websites and mobile apps such as:
Websites:
1. Smart Corporate Website
2. Smart Online Store
3. My Smart 
4. Smart Paywall (Smart Postpaid, Smart Prepaid, Bro Dashboard)
5. Smart Facebook Chatbot
6. TNT Corporate Website
7. TNT Online Store
8. TNT Paywall
9. Spinnr

Mobiles Apps:
1. TNT App
2. Smart Infinity Lifestyle app
3. RoamFree mobile app
4. Smart Roamer mobile app
5. Ka-Partner mobile app
6. Link ALL mobile app
7. CARA mobile app
8. MyCloudPH
9. Spinnr mobile app
 
And from our subsidiaries, affiliates, and third-party business partners to whom you have given your consent for them to share your information with us.


When we disclose personal information
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 information is disclosed on a confidential basis, through secure channels, and only in compliance with the Data Privacy Act.

We will never share, rent, or sell your personal information to third parties outside of the Smart Communications, Inc. except in special circumstances where you may have given your specific consent for, and as described in this policy.

In some instances, we may be required to disclose your personal information 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. This includes partner companies, organizations, or agencies, and their sub-contractors. For example:  our couriers for bill delivery and our customer contact centers for our pre- and post-sales hotline operations;

• Our Subsidiaries and Affiliates with whom you have also signed-up with. We do so only for the improvement of each other’s business and operations. For example: we share information about your credit standing to facilitate your service applications with them, resulting in faster approvals;

• Other companies to whom you have also given consent for us to share your information with; and

• Law enforcement and government agencies, but only when required by laws and regulations and other lawful orders and processes. 

Our partners include, but are not limited to, the list provided under Subsidiaries, Affiliates and Partners.

  
How we protect your personal information

The integrity, confidentiality, and security of your information are important to us. That’s why we strictly enforce our Privacy Policy within Smart Communications, Inc. 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;

• We restrict access to your information only to qualified and authorized personnel who are trained to handle your information 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 National Privacy Commission, when sensitive personal information 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.


Smart Communications, Inc. will not collect, use, or disclose your personal information for any purpose other than those identified in this Commitment, your Service Agreement or our Terms of Service, and any other purpose that you may have given your consent for.

For greater clarity, unless you provide specific consent, we will not:

• Share your personal information with or sell it to our business partners and third-party service providers; or

• Use your personal information to enable third-party targeted advertisements.


What your choices are

You are afforded certain rights in relation to your personal data under the Data Privacy Act. We would like to ensure that we have your consent to continue to collect, use, and disclose your personal information for the purposes that we have identified. At the same time, we want you to know that you do have choices and can object or withdraw your consent and/or edit your consent preferences at any time.

If you wish to have access to your personal information in our records; or you think that such personal information we have of you is incomplete, not up-to-date, or otherwise inaccurate, 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 information.

 
Smart Data Privacy Officer 
Mr. Jose Alvin G. Gendrano
6799 Ayala Ave., Makati City, 1226, Philippines
Email: dataprivacyoffice@smart.com.ph
Smart Hotline Nos. *888 or (02)888-1111

 
What happens when there are changes in our Policy
From time to time, we may update our privacy policy 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.   


You can modify your privacy settings at your convenience. Visit  http://smart.com.ph/privacy.

Website Privacy Policy

 

The policies below are applicable to the Web site and affiliate sites of Smart Communications, Inc. (SMART) found at www.smart.com.ph . Please be advised that the practices described in this Privacy Policy apply only to information gathered online at our Web site. They do not apply to information that you may submit to us offline or to Web sites maintained by other companies or organizations to which we may link or may have link through us.
By visiting our Web site, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Web site.
SMART collects personal information, voluntarily submitted by visitors to the Web site, which enables us to respond to requests for publications, distribute e-newsletters, process employment inquiries and respond to requests for more information or assistance. SMART adheres to the highest standards of ethical practices in all of our operations and is dedicated to protecting the privacy of all visitors to our Web site. Except as disclosed below, we do not sell, barter, give away, rent or permit anyone outside of SMART to use your personal information.
We occasionally use third-party agents, subsidiaries, affiliates and partners to perform functions such as creative design, marketing, analytics, programming, site maintenance, providing customer service, etc., on our behalf. These entities have access to the personal information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of any personal information collected from the Web site. They are restricted from using, selling, distributing or altering these data in any way other than to provide the requested services to the Web site.
We may also use or disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to
(a) conform to applicable law or comply with legal process served on us or the Website;
(b) protect and defend our rights or property, the Web site or our users, and
(c) act under emergency circumstances to protect our safety and security and those of our affiliates, agents and the users of the Web site or the public in general.
SMART also collects anonymous information to help us tailor the Web site to visitor interests and concerns. We use "cookies" to help us understand which parts of our Web site are the most popular, where our visitors are going and how much time they spend there. The information that is gathered through cookies is used solely to assist in improving Web site design and function. This Web site is functional without the retention of cookies. You may elect to block cookies from this site through your browser settings. SMART strives to protect the transmission of any information submitted by visitors. SMART does not warrant that transmission of data will be completely secured, and any and all submissions are at the visitor's risk.
This Web site may contain links to sites operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these other Web sites.
Please remember that any information that you may share in public areas, such as message boards or feedback sections, becomes public, and therefore this Privacy Policy does not apply to any information you choose to make public. Please be careful about what you disclose, and do not post any personal information that you expect to keep private.
The Web site is published in the Republic of the Philippines and is subject to laws of the Republic of the Philippines. If you are located in a country outside the Republic of the Philippines and voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the Republic of the Philippines. SMART shall not be liable under any circumstances for damages resulting from use of information collected from visitors to the site.
SMART may change this Privacy Policy to reflect, among others, changes in the way we collect visitor information.
Questions and comments should be directed to this email address.
Last updated: January 21, 2009
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      Cookie Policy

      At Smart, we are committed to safeguarding your personal information, and we are transparent about how we handle your personal information. Accordingly, we developed this Cookies Notice to inform you about our use of cookies across our websites. We want you to understand what cookies are, how Smart uses cookies and what your choices are.

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