Privacy Policy

SmileFokus Pte Ltd, including its affiliates (“SmileFokus”), is committed to respect your privacy and to comply with applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we collect and use personal data where SmileFokus is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.

We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first.

Software on your device may access your information. Our products or services may contain links to, or may be embedded within, other companies’ websites and services that have privacy policies of their own. Where our products or services are embedded to products and services of our customers, we require our customers to provide necessary transparency to you. This might include linking to this Policy and the relevant Supplements, or providing the transparency in integrated and embedded notices which identify us as the service provider or controller.

We collect your personal data and other information when you make a purchase, use or register into our products and services , take part in campaigns or research or otherwise interact with us. This includes following categories:

SmileFokus products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are sent to SmileFokus.

When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information.

Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. See Supplements to this Policy for more details.

When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information.

We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.

We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and SmileFokus, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and SmileFokus, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.

Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, country of residence and date of birth. You may also be able to voluntarily provide more information about yourself while creating a profile, such as a photo or avatar of your choice.

We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular SmileFokus product and/or service with other personal data we may have about you, unless such personal data was collected for a purpose, where the original purpose is incompatible with this purpose.

We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.

We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying SmileFokus and third party content.

Our legal basis for processing your personal data is dependent on the purpose for processing and may vary as described in the Supplement applicable to the product or service you are using. In general, we process your personal data under the following legal bases:

We process your personal data to perform our obligations under the Service Terms applicable to the product or service you are using, provided by us or our customers.

We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent.

We process your personal data as needed to comply with laws and regulations.

SmileFokus may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, SmileFokus will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.