Privacy policy

1. GENERAL

We appreciate your trust on us and thank you for sharing your details with us via our website, smart-expatriation.com (the “Website”). Your voluntary disclosure of your details authorizes us to contact you via email or phone call and offer you our services for the product you have opted for, imparting product knowledge and special promotional offers offered by us or our associated partners.

This privacy policy (the “Privacy Policy”) specifically addresses Smart-Expatriation's obligations in respect of the data privacy laws of France. As such, we undertake to apply, where practicable, those principles and the processes set out herein to its operations globally.

Where our operations are subject to privacy legislation other than that of France, then this Privacy Policy shall be applied so far as practicable and consistent with such local legislation.

2. COOKIE POLICY

We use "cookies," which are small text files stored on your device, to help operate the Website and collect information about online activity. For instance, we use cookies to store your preferences and settings, help with sign-in, provide targeted ads, combat fraud, and analyze site operations.

If you prefer not to allow the use of cookies, you can change your browser control to block and delete cookies. You may find, however, that disabling cookies means certain areas of the Website may not function properly.

3. CORPORATE POLICY

Smart-Expatriationshall endeavour to ensure all collection, storage, transmission and other handling or usage of personal data by us shall be done in accordance with the obligations and requirements of the Ordinance.

Where a person legitimately requests access to and/or correction of personal data relating to a user, held by Smart-Expatriation, then Smart-Expatriationmay provide and/or correct that data in accordance with the time and manner stipulated within the Ordinance.

4. TYPES OF PERSONAL DATA COLLECTED

For the purpose of carrying on our business, we collect many kinds of information in order to operate effectively and provide you the best products, services and experiences we can.

In accessing or using our Website, using or subscribing to any services provided through the Website, or viewing or accessing any information or content from this Website, you as our customer may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

  • Your name;
  • Your correspondence address, and/or billing address;
  • Account details, including account numbers, service numbers, or user accounts;
  • Payment details, including credit card and banking information;
  • Contact details, including contact name and telephone number or email address; or
  • Information for the verification of identity, including identification type and identification number.

In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a service is dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data may sometimes include, but is not limited to:

  • Your age;
  • Gender;
  • Salary range and employment details;
  • Education and Profession;
  • Hobbies and leisure activities;
  • Other related products and services subscribed to; and
  • Family and household demographics.

In support of the services offered by us, information may be automatically collected relating to those services so we may perform accurate reporting and administration of your accounts.

Our web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information so that we may better meet the demands and expectations of visitors to the Website, and take necessary actions in respect of any illegal or unlawful contents on any website visited through our web servers. The types of data may include, but are not limited to:

  • The browser type and version;
  • Operating system;
  • The IP address and/or domain name; and
  • URLs.

From time to time, you may need to provide personal data about other persons to us (e.g. users whom you have subscribed for services on their behalf). In that event, for the compliance with the Ordinance, you are required to have first obtained the authorization of such individuals before using, disclosing and transferring their personal data, including giving consent on their behalf to our possible use, disclosure and transfer of their personal data, for the purposes you would want to achieve from us. If necessary, we may require you to provide us with any supporting document as may be necessary to prove such authorization.

Under certain circumstances, telephone calls made to and from our order and/or service hotlines and/or inquiry telephone numbers may be recorded for the purposes of quality control, appraisal, as well as staff management and development. Unless expressly indicated otherwise at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims either statutory, contractual or tortious, over or to such data. At all times, care is taken to protect such recordings from inadvertent and/or unauthorized access.

Any personal data supplied by you will be retained by Smart-Expatriationand will be accessible by our employees and third parties (as applicable) for the purposes set out in this Privacy Policy or as otherwise indicated by prior notice to you.

5. USE OF PERSONAL DATA

Your personal data may be used for:

  • verifying your identity;
  • processing of your application to subscribe to our services;
  • provision of products and services to you;
  • administration and management of those products and services which you have subscribed to;
  • matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of products and services to you;
  • marketing and advertising of any products and services to you by Smart-Expatriation, related companies, agents, contractors and third party suppliers upon your consent in accordance with the prevailing requirements in the Ordinance;
  • business planning and improving products and services supply to you by Smart-Expatriation, related companies, agents, contractors and third party suppliers, which may be performed by various means including without limitation research, analyses and/or surveys;
  • processing of any benefits in connection with the supply of products and services to you;
  • analysing, verifying, enforcing contractual rights, and/or checking of your credit, payment and/or status in relation to supply of products and services to you;
  • processing of any payment instructions, direct debit facilities and/or credit facilities in relation to supply of products and services to you;
  • enabling the daily operation of your account and/or the collection of amounts outstanding in your account with Smart-Expatriationincluding the use of debt collection agents;
  • enabling Smart-Expatriationto comply with any obligations to interconnect, with other industry practices, or with obligations to third parties or government agencies in relation to the supply of products and services to you;
  • maintaining and developing our business systems and infrastructure, including testing and upgrading of these systems;
  • keeping you informed about products and services supplied to you and other products and services made available by Smart-Expatriation;
  • prevention, detection or investigation of crime;
  • disclosure as permitted or required by law; and/or
  • any other purposes as may be agreed to between you and Smart-Expatriation, including the purposes set out in any application or terms and conditions for the supply of specific products and services.

6. ACCURACY OF PERSONAL DATA

Where possible, Smart-Expatriation will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, the data provided will be validated against preexisting data held by Smart-Expatriation.

We fully comply with the “rights of access and correction” obligations of the Ordinance. Please refer to the section titled “Access and Correction of Personal Data” below for details on how you can obtain and correct any personal data relating to you that Smart-Expatriation may hold.

Please note that the accuracy of such personal data we collect, use and disclose depends to a large extent on the information you provide. You have a right to request correction of your personal data and we recommend that you:

  • let us know if there are any errors in your personal data; and
  • keep us up-to-date with changes to your personal data such as your name or email address.

7. RETENTION OF PERSONAL DATA

Smart-Expatriationwill destroy any personal data it may hold in accordance with its internal policy. Generally speaking, our policies cover the following principles:

  • personal data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
  • personal data are purged based on the above criteria from Smart-Expatriation's electronic, manual, and other filing systems in accordance with Smart-Expatriation's internal procedures.

8. DISCLOSURE OF PERSONAL DATA

All personal data held by Smart-Expatriation will be kept confidential but Smart-Expatriation may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

  • any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with Smart-Expatriation;
  • any person or company who is acting for or on behalf of Smart-Expatriation, or jointly with Smart-Expatriation, in respect of the purpose or a directly related purpose for which the data was provided;
  • any other person or company who is under a duty of confidentiality to Smart-Expatriation and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
  • Smart-Expatriation’s agents, contractors, suppliers, information service providers and content providers; its professional advisers, including its accountants, auditors and lawyers;
  • government and regulatory authorities and law enforcement agencies and other organisations, as required or authorised by law;
  • any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureaux, or collection agencies, security agencies, necessary to establish and support the payment of any services being requested;
  • your authorized representatives or your legal advisers when requested by you to do so;
  • organisations who manage our business and corporate strategies (and for such purposes), including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our corporate risk and funding functions (e.g. securitisation); and
  • any proposed or actual participant, assignee or transferee of all or any part of Smart-Expatriation's operation or business.

Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information.

9. SECURITY OF PERSONAL DATA

Personal data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas.

Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a “need to know” basis that is commensurate with Smart-Expatriation’s policy.

Where Smart-Expatriationholds, uses and/or transmits the customers’ personal data it will be adequately protected from accidental and/or unauthorized disclosure, change and/or destruction.

You should be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the internet.

10. LINKS TO THIRD PARTY WEBSITES

Our Website may contain links to other sites and pages which are operated by third parties. We have no control over the content of the linked websites or the way in which the operators of those websites deal with your personal data.

You should review the privacy policy for those third party websites to understand the ways in which your personal data may be used by those third parties.

11. ACCESS AND CORRECTION OF PERSONAL DATA

Under the Ordinance, you have the right to request access to or correction of the personal data provided. Such requests should be made in writing and sent to us by mail. Smart-Expatriation will, upon satisfying itself of the authenticity and validity of the access or correction request, make every endeavour to comply with and respond to the request within the period set by the Ordinance.

12. DIRECT MARKETING

In accordance with the requirements of the Ordinance, Smart-Expatriationwill honour your request not to use your personal data for the purposes of direct marketing.

Upon your consent, Smart-Expatriationmay use his or her personal data (including name, contact information, and information about the products or services that he or she has purchased or subscribed to) to deliver to customer, through various communication channels by using email address, correspondence address, mobile phone number, telephone number, service number and service account number, etc.

You can at any time send request to Smart-Expatriationtogether with registered name and service account number, registered service number or login name, to stop receiving the promotion materials aforesaid or to start receiving the same (if you have unsubscribed from receiving such materials before). Any such request should clearly state the details of the personal data in respect of which the request is being made.

13. CHANGES AND UPDATES

This Privacy Policy may be amended from time to time and all handling of personal data will be governed by the most recent version of this Privacy Policy, available on our Website.