Privacy Policy

 

This is the Privacy Policy of Smart Union Pte. Ltd. and its Associated Entities (collectively referred to as “Smart Union” or the “Group”) and it applies to all personal data you provide to the Group when you access the Group’s websites (“Group’s Websites”) and when you use the Group’s web services.

 

By providing us with your personal data when you access or view the Group’s Websites or use the Group’s web services via the Group’s Websites, you consent and agree to the Group collecting, using, and disclosing your personal data in the manner set out in this Privacy Policy.

 

This Privacy Policy is effective as of 1 January 2024.

 

1. Group’s websites

• smartunion.global

• smartunion.ae

 

2. Collection, use and disclosure

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Smart Union offers a variety of web services that are collectively referred to as the “Services”. Smart Union collects personal data from individuals who visit the Group’s Websites (“Visitors”) and individuals who register to use the Services (“Customers”).

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Smart Union is committed to protecting your personal data and complying with all appropriate legislation. This document details:

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2.1 What personal data do we collect?

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2.2 Why and how do we use the personal data?

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2.3 With whom do we share the personal data?

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2.4 Your rights relating to the personal data

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2.5 How to contact us

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Notwithstanding any other provision in this Privacy Policy, you agree that Smart Union shall be entitled to use and disclose any information and feedback arising from your use of the Services, subject to such information and feedback being anonymised and such use and disclosure being in compliance with applicable privacy laws.

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2.1 What personal data do we collect?

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When you use the Services (such as when you request information through our Group’s Websites), Smart Union may collect, amongst others, the following information.

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• First and Last Names

• Business email address

• Phone number

• Group Name

• Job Level

• Industry

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If you visit the Group’s Websites, we may also collect information about your device used to access the Group’s Websites, your web browser type and language, your Internet Protocol (IP) address and geographic data associated with the IP address etc.

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2.2 Why and how do we use the personal data?

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The personal data is collected, used, disclosed and/or processed for the following purposes:

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• provide and deliver the Services you have requested;

• create Customer profiles and give the Customer access to the Services;

• operate our internal operations, systems, products, and services;

• understand the Customers’ and Visitors’ experiences with a view to enhance the Customers’ and Visitors’ experiences of our services and products;

• provide customer service related to our products and services;

• send service-related information associated with our products and services, including confirmation but not limited to actions taken (e.g. change of password), invoices raised, updates and enhancements, security alerts plus support and administrative messages;

• provide updates on promotions, upcoming events, and news about our products and services; and

• facilitate any proposed or confirmed merger, acquisition or business asset transaction involving any part of the Group and/or its related corporations, or corporate restructuring process.

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In addition, personal data that is uploaded by the Customer (either directly by the Customer using CSV, Google Sheets or via an authenticated API connection) is used to derive KPIs (Key Performance Indicators). These KPIs are either predefined by Smart Union or defined by the Customer.

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2.3 With whom do we share the personal data?

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Smart Union may disclose personal data about you to the following third parties for any of the purposes described in this Privacy Policy:

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• any person to whom you authorise us to disclose your personal data;

• law enforcement agencies, relevant government ministries, regulators, statutory boards or authorities in compliance with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;

• our professional advisors, which may include lawyers, auditors, accountants or other consultants; and

• service providers we hire to perform services on our behalf, including, but not limited to the generation of invoices and bills, managing credit card payments for the Services, and managing our information technology systems. These service providers do not have the right to use your personal data for their own purposes. If you have consented, Smart Union may share your personal data with the Group’s service providers so that these service providers can contact you on our behalf.

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From time to time, Smart Union may partner with other persons to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Smart Union, the Group may share your personal data with our joint promotion partner(s). Smart Union does not control our business partners’ use of your personal data or whether their use of the personal data will be in accordance with their own privacy policies. If you do not wish for your personal data to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

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2.4 Your rights relating to the personal data

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2.4.1 Access

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You are entitled to request access to a copy of the personal data which we hold about you or information about the ways in which your personal data has been or may have been used or disclosed by us, using the form available here.

 

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the estimated fee before processing your request. We reserve the right not to provide access to the personal data until you have paid the access fee.

 

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 calendar days of receiving your request, we will inform you in writing within 30 calendar days of the time by which we will be able to respond to your request and/or the reasons we are unable to do so.

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2.4.2 Correction

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You are entitled to request to correct an error or omission in the personal data which we hold about you, using the form available here.

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We will respond to your request as soon as practicable. Should we not be able to respond to your request within 30 calendar days of receiving your request, we will inform you in writing within 30 calendar days of the time by which we will be able to respond to your request and/or the reasons we are unable to do so.

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2.4.3 Withdrawal of consent

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The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing.

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You are entitled to withdraw any consent you have provided to us previously and to request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed herein, by submitting your request using the form available here. Please note that we are generally not obliged to forward any request for withdrawal of consent to any third party to whom we have disclosed your personal data – such request should be made directly with such third party.

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Upon receipt of your written request 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 and for us to notify you of the consequences of us acceding to the same. We will respond to your request as soon as reasonably possible. In general, we shall seek to process your request within 10 working days of receiving it. Should we not be able to respond to your request within 10 working days of receiving your request, we will inform you in writing within 10 working days of the time by which we will be able to respond to your request.

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Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose your personal data where such collection, use and/or disclosure without consent is permitted or required under applicable laws and regulations. Further, we are generally not obliged to delete or destroy personal data after your withdrawal of consent (but such personal data will continue to be protected and retained in accordance with our internal policies and applicable laws and regulations).

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2.4.4 Automated profiling

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We use anonymised data in our profiling activities.

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2.5 How to contact us

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You may submit your queries, feedback or requests in writing or via email to our Data Protection Officer at the contact details below:

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Attention: Data Protection Officer

Email: dpo@smartunion.global

Address: Smart Union Pte. Ltd.

190 Middle Road #14-05

Singapore 188979

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3. Website navigational information

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Smart Union uses commonly-used information-gathering tools, such as cookies and web beacons, to collect information as you navigate the Group’s Websites (“Website Navigational Information”). This section describes the types of Website Navigational Information that may be collected on the Group’s Websites and how this information may be used.

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3.1 Cookies

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Smart Union uses cookies to make interactions with the Group’s Websites easy and meaningful. When you visit the Group’s Websites, Smart Union’s servers send a cookie to your computer. Such cookies do not personally identify you.

 

They merely recognise your Web browser. Unless you choose to identify yourself to Smart Union, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me”), you remain anonymous to the Group. Smart Union uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer.

 

Persistent cookies remain on your computer after you close your browser software or turn off your computer.

If you have chosen to identify yourself to Smart Union, the Group uses session cookies containing encrypted information to allow the Group to uniquely identify you. Each time you log into your web account in relation to the Services, a session cookie containing an encrypted, unique identifier that is tied to your web account is placed on your browser. These session cookies allow the Group to uniquely identify you when you are logged into the Services and to

process your online transactions and requests. Session cookies are required to use the Services.

 

Smart Union uses persistent cookies that only the Group can read and use to identify browsers that have previously visited the Group’s Websites. When you purchase the Services or provide the Group with personal data, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that the Group places on your web browser. The Group is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Group does not store account numbers or passwords in persistent cookies. If you disable your web browser’s ability to accept cookies, you will be able to navigate the Group’s Websites, but you will not be able to successfully use the Services.

 

Smart Union may use information from session and persistent cookies in combination with anonymized personal data about the Group’s Customers to provide you with information about the Group and the Services.

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3.2 Web Beacons

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Smart Union uses web beacons alone or in conjunction with cookies to compile information about Customers’ and Visitors’ usage of the Group’s Websites and email interactions with the Group. Web beacons are clear electronic images that can recognise certain types of information such as cookies on your computer when you view a particular website tied to the web beacon. For example, Smart Union may place web beacons in marketing emails that notify the Group when you click on a link in the email that directs you to one of the Group’s Websites. Smart Union uses web beacons to operate and improve the Group’s Websites and email communications.

 

Smart Union may use information from web beacons in combination with anonymized personal data about the Group’s Customers to provide you with information about the Group and the Services.

 

3.3 Flash Cookies

 

Smart Union may use local shared objects, also known as flash cookies, to store your preferences or display content based upon what you view on the Group’s Websites to personalise your visit. Third parties with whom the Group partners to provide certain features on the Group’s Websites or to display advertising based upon your web browsing activity use flash cookies to collect and store information.

 

3.4 IP Addresses

 

When you visit the Group’s Websites, the Group collects your Internet Protocol (“IP”) address(es) to track and aggregate non-personal data. For example, Smart Union uses IP addresses to monitor the regions from which Customers and Visitors navigate the Group’s Websites.

 

3.5 Third Party Cookies

 

From time-to-time, Smart Union engages third parties to track and analyze usage and volume statistical information from individuals who visit the Group’s Websites. Smart Union may also use other third-party cookies to track the performance of Group’s advertisements. The information provided to third parties does not include personal data, but this information may be re-associated with personal data after the Group receives it.

 

Smart Union may also contract with third-party advertising networks that collect IP addresses and other Website Navigational Information on the Group’s Websites and emails and on third-party websites. Such advertising networks track your online activities over time by collecting Website Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about these and other advertising networks and their opt-out instructions, click here.

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3.6 Links to other websites

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The Group’s Websites may contain links to other websites of interest. However, once you have used these links to leave the Group’s Websites, you should note that we do not have any control over such third parties’ websites. Therefore, we cannot be responsible for the protection of the privacy of any personal data which you may provide whilst visiting such third party websites. You should exercise caution and review the privacy policy(ies) of such third party websites before disclosing your personal data to such third parties.

 

4. Public forums and customer testimonials

 

Smart Union may provide bulletin boards, blogs, or chat rooms on the Group’s Websites. Any personal data you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Smart Union is not responsible for the personal data you choose to submit in these forums.

 

Smart Union may post a list of Customers and relevant testimonials on the Group’s Websites that contain personal data such as Customer names and titles. Smart Union will obtain the consent of each Customer prior to posting any such personal data.

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5. International transfer of personal data collected

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To facilitate Smart Union’s global operations, the Group may transfer and access the personal data of Smart Union’s Customers from anywhere in the world. This Privacy Policy shall apply even if Smart Union transfers the personal data of Smart Union Customers to other countries.

 

6. Communications preferences

 

Smart Union offers Customers and Visitors who provide contact information a means to choose how the Group uses the information provided. If you have previously consented to but no longer wish to receive marketing and non-transactional communications, please click on the “unsubscribe” link located at the bottom of the Group’s marketing emails. Alternatively, you may send a request specifying your communication preferences to dpo@incorp.asia. Customers cannot opt-out of receiving transactional emails related to their account with Smart Union or the Services.

 

7. Security

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Smart Union uses appropriate administrative, technical, and physical security measures to protect personal data of Smart Union Visitors and Customers.

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8. Changes to this privacy statement

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Smart Union may amend this Privacy Policy from time to time. Smart Union will provide notification of the material changes to this Privacy Policy on the Group’s Websites at least thirty (30) business days prior to the change(s) taking effect.