Smart Cloud (“Smart Cloud”) respects the privacy of individuals with regards to their personal data (“Personal Data”) and is committed to protecting the privacy of our customers, contestants, participants, subscribers (“Users”). In accordance with the Singapore Personal Data Protection Act (PDPA) 2010 (“Act”) and General Data Protection Regulation (GDPR) (EU), this privacy policy describes how your Personal Information is collected and used and informs your choices with respect to your Personal Data. The following discloses our information gathering and dissemination practices.

This Policy applies to all personal data that you may provide to us and the personal data we hold about you when you subscribe to our services. By providing us with your personal data or by accessing, using or viewing the applicable website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the relevant website(s) and/or service(s) and DO NOT provide any personal data to us.

  1. What This Privacy Statement Explains

This Privacy Statement explains:
• What kind of personal information we collect
• How we collect your personal information
• How we use your personal information
• When we disclose your personal information
• How we handle marketing subscription
• Your rights to your information
• Security of your information
• Self-Access to your information
• Obligations of the individuals
• Limits to your information

  1. Our Commitment To You
    We value your trust and are committed to protecting your personal information. To ensure that you can make informed decisions and feel confident about supplying your Personal Information to us when using Smart Cloud websites, Products and/or Services, we provide you with this Privacy Statement outlining our practices and the choices you have concerning how your Personal Information is being collected and used by us.
  2. Defining Personal Information
    Personal information refers to any information which relates directly or indirectly to you. This includes any information that can be used to distinguish, identify or contact you. For the purposes of this Privacy Statement, personal information encompasses sensitive personal information which relates to information relating to your health, political opinions, religious beliefs, etc. For the avoidance of doubt, please note that this Privacy Statement is applicable only if you are a natural person/an individual.
  3. What Kind of Personal Information We Collect
    In order for us to provide you with our Products and/or Services and to operate in an efficient and effective manner by providing you with the best service possible, we need to collect relevant personal information from you. The personal information collected by us may include (but is not limited to) the following:
    • contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, current private and/or business address, telephone or mobile phone number, fax number, email address
    • your credit card information and bank account details
    • the status of the Products and/or Services you have acquired from us or subscribed to
    • how you use the Products and/or Service (for example the website that you hosting and emails that being send out or receive.)
    • recording of calls placed by you to our helpdesk for our service enhancement and improvement
    • information and data submitted in ticket or email to our ticket system
  4. When And How We Collect Your Personal Information?
    We may collect personal information directly from you when you:
    • communicate with us (for example when you submit an application form to become our customer, or when you contact us for any enquiries including by calling our customer service)
    • register or subscribe for a specific Product and/or Service
    • use Products and/or Services of Smart Cloud
    • participate in any of our surveys
    • enter into or participate in any competitions, contests or loyalty programmes run/organised by us
    • commence a business relationship with us (for example, as a service provider/business partner)
    • visit any of our offices
    • visit or browse our websites
    • lodge a ticket to our ticket system
    • provide feedback to us (for example via our websites or in hard copy) Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.
  5. How We Use Your Personal Information
    We may collect and use personal information from you or from the category of third parties identified in this Privacy Statement, for one or more of the following purposes:
    • to verify your identity
    • to assess and process your application(s) /request(s) for our Products and/or Services
    • to provide you with the Products and/or Services you have requested
    • to administer and manage the Products and/or Services we provide you (including charging, billing, facilitating payments and collecting debts)
    • to investigate and resolve any service issues, billing queries, complaints or other enquiries that you submit to us regarding our network, Products and Services with our customer relations teams
    • to assess and/or verify credit worthiness
    • to detect and prevent fraudulent activity
    • to keep in contact with you and provide you with any information you have requested
    • to engage in business transactions in respect of Products and/or Services to be offered and provided to you
    • to establish and better manage any business relationship we may have with you
    • to process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
    • to help us monitor and improve the performance of our Products and Services, our customer relations teams and Smart Cloud Websites and to make these more efficient
    • to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems
    • to manage staff training and quality assurance
    • to notify you about benefits and changes to the features of our Products and/or Services
    • to determine how can we improve services to you
    • to produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
    • to investigate, respond to, or defend claims made against, or involving Smart Cloud.
    • to conduct marketing activities (for example, market research)
    • to maintain records required for security, claims or other legal purposes
    • to comply with legal and regulatory requirements
    • for any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities
  6. Disclosure of Your Personal Information
    As a part of providing you with our Products and/or Services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:
    • law enforcement agencies
    • government agencies
    • companies and/or organisations that act as our agents, contractors, service providers and/or professional advisers
    • companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with Products and/or Services that you have requested or subscribed for
    • other parties in respect of whom you have given your express or implied consent subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to Smart Cloud.
  7. Direct Marketing
    For customers who opt-in to our marketing, we may use your personal information to provide you with information about our and third party services and/or products, which may be of interest to or benefit you, except where otherwise requested or notified by you.

If you do not wish your personal information to be utilised for the purposes of marketing or should you change your mind in relation to your previous decision, you can log into our customer billing control panel to opt-out, or contact us for assistance.

  1. What If Personal Information Provided By You Is Incomplete?
    Where indicated (for example in registration/application forms), it is obligatory to provide your personal information to us to enable us to process your application for our Products and/or Services. Should you decline to provide such obligatory personal information, we will not be able to correctly verify your legitimate identity and therefore we may not be able to process your order to provide you with our Products and/or Services.
  2. Your Rights To Your Personal Information
    Customers has the following rights of personal information with Smart Cloud:

– Right of access
– Right to rectification
– Right to erasure
– Right to data portability
– Right to restrict of processing
– Right to object/withdraw consent
– Right to complain to authority

Our customer billing control panel allows customer to access, rectify, erase, opt-in or opt-out from marketing, as well as to request a copy of their personal data or withdraw their personal data from our system. Should you need any assistance to perform any of the rights, please contact us.

  1. Retention Limit
    Smart Cloud will retent Customer’s personal information for the period of the subscription of services from us. Should the customer no longer has any services with us and is inactive without access for more than THREE (3) years, we will remove them from our system.
  2. Security of Personal Data
    All transfer of personal data, be it for modification or transmission, are all securely encrypted with SSL. All backups of personal data are also stored internally within Smart Cloud’s environment.
  3. Minimum Age of Consent
    Customer has to be of a minimum age of SIXTEEN (16) years old in order to provide their personal information for the purpose of subscribing of services from Smart Cloud.
  4. Your Obligations
    You are responsible for providing accurate and complete information to us about yourself and any other person whose personal information you provide us and for updating this personal information as and when it becomes incorrect or out of date by logging into our customer billing control panel. This obligation is a condition to the provision of our Products and/or Services to you and/or any other person authorised or permitted by you or your organisation/company to use the Products and/or Services.

In the event you may need to change the personal information in our system to another third parties (for example to your spouse or children or where you are the designated person in charge (from an organisation or company) for dealing with us, if you are acquiring and are responsible for a service and/or product that they will use), you confirm that you have (i) obtained their consent or otherwise entitled to provide their personal information to us and for us to use accordingly, and (ii) informed them to read this Privacy Statement.

  1. Online Dealings With Smart Cloud
  2. a) Cookies
    We collect information about your use of our websites from cookies. Cookies are packets of information stored in your computer which assist your website navigation by customizing site information tailored to your needs. Cookies in themselves do not identify the individual user, just the computer used. You are not obliged to accept cookies. If you are concerned, you can set your computer either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. However, rejection of cookies may affect your use of our websites as we will be unable to personalize aspects of your use of the website.
  3. b) Links to Third Party Websites
    Please be informed that this Privacy Statement applies solely to Smart Cloud Websites and does not apply to any third party websites you may access from our websites. To determine how they deal with your Personal Information, you should ensure that you read their respective privacy policies.
  4. Updates To Our Privacy Statement
    We may amend this Privacy Statement from time to time and the updated version shall apply and supersede any and all previous versions, including but not limited to, leaflets or hard copy versions. Please check our website for information on our most up-to-date practices.
  5. Governing Laws
    This Policy is governed by the laws of Singapore & EU. You agree to submit to the exclusive jurisdiction of the Courts of Singapore or EU in any dispute relating to this Policy.
  6. Self-Access to Personal Data
    Smart Cloud’s Customers will be able to have self-access to their personal data through our billing control panel.
  7. Our Contact Details
    If you have any questions or clarifications relating to the collection or usage of your personal data, you are welcome to email our privacy representative