Section A: Definitions and consent

1. Personal information refers to any information that you voluntarily submit to us (e.g. when signing up for our e-book), that identifies your personality (e.g. contact information, such as name, email address, or other information about yourself or your business)
   • We may also collect navigation information, such as IP address, geographical location, browser type, referral source, length of visit and pages viewed.
2. By accessing this website, you consent to our privacy policy
3. We reserve the right to make changes to this policy
4. Any change will be posted on this page.

 Section B: What kind of data will be collected?

1. You are free to explore the websites without providing any personal information about yourself.
2. During the course of travel on our website, you may be asked to provide information about yourself, depending on your agreement (e.g. filing a form for free e-book), such as name or email address.
3. And by providing contact information to us, you may be asked for additional information from us so as to provide a more personalized service for you.
4. When visitors apply for job with iSmart Communications, we may also require you to submit additional personal data as well as a resume or curriculum vitae.
5. As you navigate our websites, iSmart Communications may also collect information through the use of gathering tools, such as cookies and web beacons.
6. Social media features
   • Websites that include social media features, such as Facebook’s “like” buttons and widgets, such as “Share this” button or interactive mini-programs that run on our sites. And these features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly.
7. External websites
   • External websites refers to the links that we provide through the content in our websites, such as blog posts, that links to other websites.
   • Our provision of such links does not constitute our endorsement of these other websites, their content, their owners or their practices
8. Log files
   • When you use service or view content provided by iSmart Communications, we automatically collect information about your computer hardware and software.
   • Include IP address, browser type, domain names, internet service provider, files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website service, to maintain quality of the subscription service, and to provide general statistics regarding use of the iSmart Communications website.

 **Use of Cookies

• Why use cookies?
• We use first-party and third-party cookies for (1) technical reasons – cookies are required in order for the websites to operate (Strict necessary cookies), (2) enable us to track and target the interests of our users to enhance the experience on our website.
• This data is used to deliver customized content and promotions within the iSmart Communications website to visitors whose behaviour indicates that they are interested in a particular subject area.
• What types of cookies do we use and how do we use them?
• Essential website cookies
• Performance and functionality cookies
• Analytics and customization cookies
• Advertising cookies
• Social networking cookies

How can I control cookies?

• You can set or amend your web browser controls to accept or refuse cookies.
• If rejected, you may still use our website though your access to some functionality and areas of our website may be restricted.
• As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser
• Most advertising networks offer you a way to opt out of targeted advertising
• Essential website cookies: because these cookies are strictly necessary to deliver the websites to you, you cannot refuse them.

Section C: Why collect these data? How would these data be used?

1. Use of personal information
   • To improve your browsing experience by personalizing the websites and to improve the subscription service
   • Send information or the iSmart Communications content to you, which we think may be of interest to you by email, or other means and send you marketing communications relating to your business.
   • Promote use of our services to you and share promotional and information content with you in accordance with your communications preferences.
   • For statistical information and calculation about our users gathered in marketing software, such as HubSpot, but this information will not be used to identify any individual users.
   • Send information to you regarding changes to our customer terms of service, privacy policy (including cookie policy), or other legal agreements.
   • Meet legal requirements, court orders, etc.
2. Use of information collected through subscription, or form-filling for the purpose of:
   • Sending information; responding to enquiries, and/or other requests or questions.
   • Marketing to our mailing list or continuing to send emails to our clients after the original transaction has occurred.
3. Use of navigational information
   • Use navigational information to operate and improve the websites and the subscription service
   • May also use it alone or in combination with personal information to provide you with personalized information about iSmart Communications.
4. Customer Testimonials and Comments
   • Post customer testimonials and comments on our website, which may contain personal information.
   • We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
5. Social media features
   • Websites that include social media features are either hosted by a third-party or hosted directly on our website, and thus this privacy policy does not apply to these features, as your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
6. External websites
   • Our website provides links to other websites, and we do not control and are not responsible for, the content or practice of these other websites.
   • Our provision of each link does not constitute our endorsement of these other websites, their content, their owners or their practices.
   • Privacy policy does not apply to these other websites.

Section D: When will the information be collected?

• When you fill out a form, or enter information on our site
• When you register, respond to survey or marketing communication, surf the website, or use certain other site features, e.g. sharing blog posts on social media
• During the course of travel on our website, you may be asked to provide information about yourself, depending on your agreement (e.g. filling up a form for free e-book), such as name or email address.
• And by providing contact information to us, you may be asked for additional information from us so as to provide a more personalized service for you.

Section E: Protection of data and our promise

1. Data subject requests
   • Can ask us to update, change or delete any information iSmart Communications holds about you.
   • Requests to access, change or delete your information will be handled within 28 days.
2. Retention Period
   • How long we keep information we collect about you depends on the type of information, as described in further detail below.
   • After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
   • When we have no on-going legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
3. Commitment to security and protection of data
   • Protecting your personal information is important to us. We take extra steps and follow industry best practices to ensure these are protected from misuse and loss and from unauthorized access.
   • We comply with our data protection obligations pursuant to the Singapore Personal Data Protection Act 2012. We assure you that any and all information collected will only be used in accordance with the terms in this Privacy Policy.
   • Maintains tight controls over data, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure.
   • We use CRM services from HubSpot to store data about our prospective and current customers. We use Google Analytics as a platform for iSmart Communications’ own website analysis. And we use HubSpot as a marketing automation tool where store data related to our marketing activities. 
   • We are committed to protect our Digital Assets and we conduct Vulnerability Assessment (VA) on a periodic basis to identify gaps and address any vulnerabilities.
4. Use of data
   • Freedom of choice and the right to know
   • We promise that you are free to explore the website without providing any personal information about yourself.
   • If we intend to use your personal information for a secondary reason, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
   • iSmart Communications acknowledges that you have the right to access your personal information.
   • If we are being required to remove the data, we will respond within 28 days
   • Compelled disclosure
   • We may also disclose your personal information if required by law to do so and/or compelled by a Court order and/or in accordance with the exceptions set out in the Singapore Personal Data Protection Act and/or any applicable law.
   • Third-party disclosure
   • We do not sell, trade, or otherwise transfer to outside parties about your personal information and/or sensitive information
   • Spamming
   • SPAM CONTROL ACT (SINGAPORE): Law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
5. Child protection – Children Online Privacy Protection Act (COPA)
   • What operators of websites and online services must do to protect children’s privacy and safety online?
   • Our websites are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13.
   • If you believe that we have collected such information, please contact us. 
6. Corporate Events
   • If we are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by HubSpot on the websites and the subscription service.
   • In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, 
     and choices you may have regarding your personal information.
7. Compelled disclosure
   • We reserve the right to use or disclose your personal information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

 Section F: GDPR (Applies to EU users)

• You can find out if we hold any personal data by making a “data subject access request” under General Data Protection Regulation (GDPR). If we hold information about you, we will
• Give you description of it
• Tell you why we are holding it
• Tell you who it could be disclosed to and to whom
• Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
• Let you have a copy of the information in the intelligible form,
• Give you other information as outlined in the Article 15 of the GDPR
• You can ask us to restrict the processing of your personal data if (i) you contest their accuracy, (ii) the processing is unlawful and you do not want to delete the data, (iii) we do not need the personal data for the purpose of processing but you need them for the establishment, exercise or defence of legal claims, (iv) where you objected to the processing in accordance with Article 21(1) of GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.
• Have the right to receive any personal data concerning you, which you have provide to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us.
• Article 20 of the GDPR applies to this.
• Have the right to object, on grounds relating to your particular situation, at any time to our processing of personal data concerning you which is based on Article 6(1) (Public interest, official authority, legitimate interests), including profiling based in those provisions

Section G: How to access and control your personal data

• Reviewing, correcting and removing your personal information.

You have the following data protection rights:

• You can request access, correction, updates or deletion of your personal information
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.
• Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent
• You have the right to complain to a data protection authority about our collection and use of your personal information.
• Anti-spam policy
• We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service
• To unsubscribe from our communications
• May unsubscribe from our marketing communications by sending us email.
• Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.

Section H: Contact us

If you have further questions regarding the privacy policy, feel free to contact us by e-mail: dpo@ismartcom.com.