1. Who we are and what this policy covers
This Privacy Policy applies to the Smartel website (the “Website”), operated by SMARTEL INFORMATION TECHNOLOGY LIMITED (“Smartel”, “we”, “us” or “our”), a company headquartered in Hong Kong. We are an international advertising, marketing and cloud communication company offering value-added services including international SMS, SMS verification, SMS marketing, international voice, global numbers, WhatsApp Business and Viber Business messaging.
For personal data collected through the Website or through direct contact with us, we are the “data user” under the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong) (the “PDPO”). By using the Website you acknowledge that we handle your personal data as described here. If you do not agree, please do not send us personal data.
This policy does not cover (a) personal data that our customers send through our messaging and voice services — see Section 10 — or (b) websites and services operated by third parties that the Website may link to.
2. Personal data we collect
2.1 Information you give us
- Direct communication. The Website does not have an online form. If you email or call us using the contact details shown on the Website, we receive the information you choose to provide, such as your name, company, job title, email address, phone number, the products you are interested in, and the content of your message.
2.2 Information collected automatically
- Technical data. Like most websites, our web server receives your IP address, browser type and version, device and operating system, the pages requested, the referring page and the date/time of access. These server logs are used for security, diagnostics and capacity planning.
We do not intentionally collect sensitive personal data (such as health data, identity-card numbers or payment card details) through the Website. Please do not include such information in emails to us.
3. How and why we use personal data
- Respond to enquiries and provide quotes or trials. To reply to your email or call, assess your requirements, connect you with the right solution consultant and follow up on your enquiry.
- Operate, secure and improve the Website. To keep the Website available and secure, detect abuse, debug issues and improve content and performance.
- Business communications. To send you information about our products and services that relates to your enquiry or business role. We will not use your personal data for direct marketing without the consent required by the PDPO, and you can opt out at any time (Section 8).
- Comply with law and protect rights. To meet legal, regulatory and compliance obligations, and to establish, exercise or defend legal claims.
We use personal data only for the purposes above or a directly related purpose. If we need to use it for a new purpose, we will obtain your prescribed consent first, as the PDPO requires.
4. Our approach under the PDPO
We handle personal data in line with the six Data Protection Principles in Schedule 1 of the PDPO:
- Purpose and manner of collection we collect only data that is necessary and not excessive for the purposes in Section 3, by lawful and fair means.
- Accuracy and retention we take practical steps to keep data accurate and do not keep it longer than necessary (Section 7).
- Use we use data only for the original purpose or a directly related one, unless you give prescribed consent.
- Security we protect data against unauthorised or accidental access, processing, erasure, loss or use (Section 7).
- Openness we make this policy available so you can see the kinds of personal data we hold and how we use it.
- Access and correction you may ask for access to, and correction of, your personal data (Section 8).
7. Retention and security
We keep personal data only as long as needed for the purposes in this policy. Enquiry records that do not lead to a business relationship are deleted or anonymised once they are no longer needed. Records connected to a contract or customer relationship are kept for the contract term plus the period required by tax, accounting, regulatory and limitation laws. Server logs are kept for a short period for security and diagnostics.
We protect personal data with technical and organisational measures, including access controls limited to authorised staff, confidentiality obligations and security monitoring. No method of transmission over the internet is completely secure; if you suspect your information has been compromised, please contact us immediately. If a personal-data breach affects you, we will notify you and the relevant authorities where required by law or where there is a real risk of harm.
8. Your rights and choices
Under the PDPO you have the right to:
- check whether we hold personal data about you, and request access to a copy of it (a “data access request”);
- request correction of personal data that is inaccurate (a “data correction request”);
- opt out of direct marketing at any time, free of charge; and
- lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).
To exercise these rights, email us at bd@smartel-hk.com with the subject “Privacy Request” and tell us which right you wish to use and what data it relates to. We may need to verify your identity first. We will respond within 40 days of receiving a valid data access or correction request, as the PDPO requires, and may charge a reasonable fee for complying with a data access request.
9. Children
The Website and our services are intended for businesses and professionals and are not directed to anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
10. Data processed through our services
When a customer uses our SMS, voice, WhatsApp Business, Viber Business or other messaging services, the recipient phone numbers, message or call content, delivery records and similar data are processed by us on the customer's instructions and for the purpose of delivering the service. In that case the customer is the data user and we act as its data processor, under the customer's service agreement and data-processing terms.
If you received a message or call sent through our platform and want to exercise privacy rights about it, please contact the sender first; you may also contact us and we will assist the sender in responding.
11. Third-party links
The Website may link to third-party websites, including those of mobile network operators, messaging platforms and partners. They have their own privacy practices, and we are not responsible for them. Please read their policies before sharing personal data.
12. Changes to this policy
We may update this policy as our Website, services or legal requirements change. The current version is always available on this page, with the date it was last updated shown at the top. For material changes we will post a notice on the Website and, where required, seek your consent again.
13. Contact us
If you have any questions about this policy or how we handle personal data, please contact: