Smart Group and Social Media Platforms Privacy Notice Smart Group recognizes the importance of personal data privacy and its protection in the digital age. We are committed to safeguarding the privacy of Smart Group users while browsing or using our websites and services. This Privacy Notice ("Privacy Notice") explains how Smart Group ensures an appropriate level of protection for personal data (i.e., information relating to an identified or identifiable natural person, directly or indirectly, through data like name, identification number, location data, online identifier, or one or more specific factors of this person; henceforth referred to as "personal data"). Specifically, this Privacy Notice will outline: 1. Who are we? 2. What personal data do we collect about you? 3. How do we collect your personal data? 4. Why do we collect and process your personal data? 5. On what legal basis do we process your personal data? 6. Who can access your personal data? 7. Where may your personal data be stored and transferred? 8. How do we ensure your personal data is secure? 9. How long do we retain your personal data? 10. Do we collect personal data from minors? 11. What are your rights? 12. How do we use cookies? 13. How does this Privacy Notice work with third-party data processing? 14. How can you contact us? This Privacy Notice applies to all services provided by Smart Group, including our websites, digital applications, contests, social media platforms, and other digital features ("our Services"). Additional privacy notices may highlight specific uses of your personal data, allowing you to opt-in or out on a case-by-case basis, including for new or other services that may have a separate privacy notice. Under data protection laws, we are required to provide you with the information in this Privacy Notice. It is important to read this notice, as well as any other notices we may provide when collecting and processing your personal data. Key Definitions for the Privacy Notice: • "We," "Our," or "Us" refers to Smart Group. • "You" or "User" refers to anyone using Smart Group’s social media platforms and services. • "Social Media Platforms" include platforms like Facebook and Twitter, media-sharing websites like Instagram, Snapchat, YouTube, and TikTok, and social media messaging apps like WhatsApp and Telegram, used by Smart Group. 1. Who are we? Smart Group is a company offering services across diverse fields, committed to empowering your business through innovative solutions tailored to your unique needs. Smart Group provides services to users in many countries. Our smartphone applications and other electronic services ("services") are operated and maintained by Smart Group. Contact Information for Smart Group: Address: Al-Ruwais District, Jeddah, Saudi Arabia Phone: +966 590 426232 Email: [email protected] If you have any questions about this Privacy Notice, including requests to exercise your legal rights, you can reach us using the information in the "How to Contact Us" section below. 2. What personal data do we collect about you? Personal data is any information about an identified or identifiable natural person, directly or indirectly. We may collect, use, store, and transfer the following types of personal data: • Identity Data: Full name, social media account details • Contact Details: Email address, phone number • Location Data: Country of residence, and approximate geographical data of your device • Marketing and Communication Data: Preferences related to receiving information from our website • Consent Records: Records of any consent you have given, with the date and time, methods of consent, and any related information (e.g., subject of the consent) • Digital Data: Social media accounts, metadata (i.e., data that describes and provides information about other data), internet identifiers like IP address, cookies, and any other data collected when visiting our website or using our app. For more information on cookies, please read our cookie notice on our websites. From Social Media Users: For social media users, we request and collect the following personal data when you interact with our social media platforms: • Identity Data: Name, surname, age, gender, profile photo, interests, list of friends/connections/followers, etc., and other public information, provided you have shared all this on your social media profile or on our accounts. • Contact Details: Email address and phone number • Location Data: Country of residence or city where you reside • Study and Work Data: Job title, current and past workplaces, educational background, etc. • Cookies and Similar Technologies: We collect personal data through your use of our social media platforms and using cookies and similar technologies, such as metadata, internet identifiers, IP addresses, and cookies collected when using our social media tools like [Facebook Insights, Facebook Pixel, Facebook Custom Audience, Facebook Lookalike Audience, X Pixel], and so forth. • Information Collected with Your Consent: You may choose to provide us with additional personal information to have a better user experience when interacting with our social media platforms or participating in promotional events, etc. This additional information will be processed based on your consent for the purposes mentioned above only. • Views and Opinions: Any opinions or other information you choose to provide to us, or publicly post about us on social media, including comments or likes on our posts and photos or messages you send to us on our social media pages. 3. How do we collect your personal data? We may collect your personal data in the following ways when you use Smart Group’s services: • Data you provide us: We receive your personal data through our websites, applications, social media platforms, or when you contact us via email, phone, or other means. • Relationship Data: We collect or receive your personal data in the regular course of our relationship with you (e.g., providing you with a service). • Public Data: We collect or receive your personal data that you have clearly chosen to make public, including via social media platforms (e.g., we may collect data from your social media profiles if you post about us). • App Data: We collect or receive your personal data when you download or use our apps. • Location Data: We collect or receive your personal data when you visit our website or use any features or resources available on or through our website. • Registration Details: We collect or receive your personal data when you use or register to use any of our websites, apps, or services. • Content and Ad Data: If you interact with any third-party content or advertisement on our website or in an app (including third-party cookies and tracking), we receive your personal data from the third party providing that content or advertisement. • Third-Party Data: We collect or receive your personal data from third parties who provide it to us (e.g., credit agencies, law enforcement authorities, etc.). 4. Why do we collect and process your personal data? We collect and process your personal data for the following purposes: • To maintain and improve our services; understand how you use our services, and enable other features; develop new services and offerings. • To tailor services to your needs and interests; provide you with customized content, such as advertisements and related services; get to know you better to offer more of what you want – more relevant information and a better user experience; learn more about which ads and information might be of greater interest to you, providing a better and more useful experience through our digital features. • To communicate with you; enable you to contact us; keep records of our communications; help resolve any issues you may have; send you promotional offers and direct marketing; keep you informed about our services, such as updates on our programs and improvements to our digital features; contact you for participation in different promotions and events. • To create and maintain a more secure and trusted environment; investigate, detect, prevent, or report fraud, misrepresentations, security breaches, or any other prohibited or illegal activities; protect our vendors, your rights and property, or the safety and integrity of our services; enforce our terms of service or any other agreements or policies in place; verify your identity. • To comply with any applicable laws or regulations; respond to a legal request for information from the government or as part of a legal proceeding; fulfill any purpose disclosed to you in connection with our services; communicate with you to resolve disputes and provide assistance with our services. • Public Interest: When necessary to perform a task in the public interest and when this task has a clear basis in law. • Vital Interest: When necessary to protect your vital interests or the interests of another natural person. For our social media platforms: By visiting and interacting with our social media platforms, Smart Group may collect personal data about you. We use the personal data we collect from you, store, and process it to provide, understand, improve, and develop our services, create and maintain a safe environment, pursue our legitimate interests, and comply with our legal obligations. Specifically, we process your personal data for the following purposes: • To provide you with content about our products or services. • To monitor the effectiveness of our advertising and promotional activities regarding our products or services on social media platforms. • To conduct market research to improve, adjust, customize, and enhance our communications and services offered to you through our social media platforms. • To address any inquiries or complaints you may have about our social media services. • To send you promotional, marketing, advertising, or other information related to our products that may interest you, based on your preferences. • To send service-related messages, support updates, account notifications, or direct messages. • When you grant us consent to process your personal data, such as when you follow our social media pages to receive notifications and messages about our activities there, or when you subscribe to our newsletters or marketing emails, or when we ask for your acceptance or rejection of data processing. Note that if you provide consent, you have the right to unsubscribe from processing for these purposes at any time and at no cost. Changing the Purpose of Processing We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the new purpose is compatible with the original one, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. Please note that we may process your personal data without your knowledge or consent, where required or permitted by law. 5. On what legal basis do we process your personal data? Depending on the processing activities at issue, we will process your personal data based on one of the following legal grounds: • Your prior consent: For example, when we offer you to register for our services and create an account, subscribe to our newsletters or marketing emails, or when we request that you take a relevant action to either accept or reject data processing; if you give your consent, you have the right to withdraw it at any time. However, in some cases, choosing not to provide your personal data or withdrawing your consent may limit your access to our services or features. For instance, you may be unable to use certain parts of our website, and we may not be able to respond to your inquiries without the necessary information. • Contractual Relationship: In such cases, processing your personal data is generally necessary to perform the contract; this means that if you do not wish for your personal data to be processed in this context, we may refuse to enter into a contract with you. • Legitimate Interest: Under data protection legislation, such as when we implement certain monitoring or tracking devices that involve processing personal data to detect and prevent online fraud. Another example is when you visit our websites and access them, even without creating an account, and enjoy the services offered by Smart Group and/or the digital features of Smart Group. By doing so, you acknowledge that we may carry out legitimate data processing as described in this privacy notice. If you do not agree to the following notice, you can stop visiting/using our websites. • Legal Obligations: Complying with legal obligations applicable to our activities. 6. Who can access your personal data? • For the purposes explained above, we will grant access to your personal information to authorized Smart Group employees and members who need to know it to process it on our behalf and who are subject to strict contractual confidentiality obligations, and may be disciplined or terminated if they fail to meet these obligations. • Additionally, we may need to transfer or allow access to third parties from the following categories: • Vendors and service providers engaged to process personal data or perform services on our behalf (based on our instructions, in compliance with our privacy notice, and subject to appropriate confidentiality and security measures); • Successors in business ownership (or those engaged in meaningful discussions about such a possibility with potential new owners of the business or company); in this respect, if ownership of all or nearly all our business changes or is subject to corporate reorganization or any other action or transfer between Smart Group entities, you acknowledge that we may need to transfer your personal data to the relevant third party (or their advisors) as part of a due diligence process to analyze any sale to a new owner or for restructuring purposes. We may also need to transfer your personal data to the restructured entity or third party following the sale or restructuring to use it for the same purposes outlined in this privacy notice; • Our media representatives; • Legal advisors, witnesses, experts, judicial and quasi-judicial authorities; to protect us from harm to the rights, property, and safety of Smart Group, our users, or the public as required or permitted by law, and to other parties to enforce applicable terms of service, including investigating potential violations; • Administrative or judicial authorities to comply with any applicable law, regulation, or enforceable government request; • Joint Controllers: In certain cases, we act as joint controllers with our social media platform providers regarding the processing of your personal data. For more information on joint control arrangements with social media platforms, please contact us as outlined in the "How to Contact Us" section below. We may also aggregate or anonymize data for public release and share it with trusted third parties and partners, such as advertisers or connected websites. For example, we may share information publicly to show trends about the general use of our services. 7. Where may your personal data be stored and transferred? Smart Group is a multinational group, and our partners and subcontractors are located in several countries worldwide. Therefore, we may need to transfer your personal data to other countries, including outside the European Economic Area, to countries where data protection laws may have lower standards than those in your country. For example, we may process your personal data on a server located outside the country where you live, and to do this, we transfer your personal data outside your country of residence. To ensure an adequate and consistent level of protection for your personal data, we will always implement appropriate safeguards to protect your personal data as outlined in this Privacy Notice. If you require more information, please contact us as indicated in the "How to Contact Us" section below. 8. How do we ensure the security of your personal data? We maintain appropriate electronic, technical, and organizational security measures, including governance frameworks, designed to protect your personal data against any accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and any other unlawful or unauthorized processing. Please note that data transmission over the internet or a website cannot be guaranteed to be completely safe from intrusion. Additionally, you must also take suitable steps to protect your personal data, including keeping your password safe and confidential. If you know or have reason to believe that your account credentials have been lost, stolen, compromised, or subject to unauthorized use, please contact us using the details provided in Section 13, "How to Contact Us," below. If we become aware of or have reason to believe that your personal data is at risk, we will notify affected users of the breach according to applicable laws. 9. How long do we retain your personal data? We will retain your personal data for as long as your account is active or as needed for the purpose for which we initially collected it. This duration may be up to 10 years. Our data retention periods are based on business needs, and data that is no longer needed will be either deleted or anonymized. We aim to maintain our services in a manner that protects data from accidental or malicious destruction. For this reason, after deleting data from our services, we may not immediately delete residual copies from our active servers, and we may not remove information from our backup systems. We may also retain your personal data for longer periods if required to comply with our legal obligations or to protect our legitimate interests. 10. Do we collect personal data from minors? Please note that you must be 18 years or older to register for our services. In some jurisdictions, the age of majority may be older than eighteen years, in which case you must meet that age to become a user. Individuals under 18 may only use our services with the involvement, supervision, and approval of a parent or legal guardian. 11. What are your rights? • **Right of Access**: You have the right to access your personal data. You can request a copy of your personal data we hold about you. In some cases, we may refuse your request, for instance, if providing the data to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. • **Right to Rectification**: We aim to keep your personal data accurate, up-to-date, and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the new data you provide. • **Right to Erasure**: You have the right to ask us to delete your personal data if there is no valid reason for us to continue processing it. You also have the right to ask us to delete your personal data if you have successfully exercised your right to object to processing, if we have processed your data unlawfully, or if we must delete your personal data to comply with the law. However, please note that we may not always be able to comply with your deletion request for specific legal reasons, which will be notified to you, if applicable, at the time of your request. • **Right to Object**: You have the right to object to the processing of your personal data when we rely on a legitimate interest (or that of a third party) and there is something about your situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data that override your rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. • **Right to Restrict Processing**: You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) if you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. • **Right to Data Portability**: You have the right to request the transfer of your personal data to you or to a third party. We will provide your personal data to you or a chosen third party in a structured, commonly used, and machine-readable format. • **Right to Withdraw Consent**: You have the right to withdraw your consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case when you withdraw your consent. 12. How does this Privacy Notice work with third-party data processing? Our services may be provided through and/or use features (such as voice control) operated by third-party platforms or may contain links to websites operated by third parties whose data handling practices differ from ours. For example: • You may be able to access our services through platforms such as gaming systems, smart TVs, mobile devices, set-top boxes, and a number of other internet-connected devices. Additionally, you may encounter third-party applications that interact with our services. These third parties have separate and independent privacy and personal data policies and terms of use. • Our digital properties may contain links to other websites beyond our control and not covered by this Privacy Notice. If you access other websites using the provided links, the operators of those websites may collect information from you that will be used by them in accordance with their privacy policies, which may differ from ours. We advise you to inquire about these policies and terms if you want to know more about how your personal data is processed by third parties. 13. How to contact us? If you have any questions, please contact us at the following email address: [email protected] 14. How can this Privacy Notice be updated? We may update the Privacy Notice from time to time in response to legal, regulatory, or operational requirements. Any changes to the Privacy Notice will be posted on this page. When these changes are significant, we may provide you with specific notice of such changes (including when they will take effect) according to the law. Where applicable (e.g., if the changes involve new data processing that may depend on your prior consent), we will ensure that you have the opportunity to agree to these changes to continue using our services or refuse – in which case you have the right to discontinue your use of our services. Updated on July 20, 2024 +966 590 426232 [email protected]