We are committed in keeping your personal information safe and secure. Read how we collect, secure, use, and disclose your information.
Smart Communications, Inc. (“SMART”, “We”, Us”) respects your fundamental right to privacy and we commit to take great care in safeguarding your personal data.
In compliance with the SIM Registration Act (Republic Act No. 11934) and with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), we share with you the principles that govern how your personal data will be collected, processed, and shared, as you register your Enterprise Extension Subscriber Identity Module (the “EE SIM”) and update your account records through the Subscriber Information Update Form.
Why we collect your Personal Data
We collect and process the following Personal Data for the purposes specified below:
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Personal Data Collected
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Purpose/s:
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| Mobile Number/s of your EE SIM/s |
To register your EE SIM and Mobile Number, as required under the SIM Registration Act.
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| Complete Name (First Name, Middle Name, Last Name) |
To register your EE SIM and Mobile Number, as required under the SIM Registration Act. Your name will be matched against the Government-Issued ID that you submit, in order to reasonably verify your identity.
In the event that the Complete Name you submit through the SIM Registration Form does not match the information we have in our account records, please expect a call-out from us to validate your information.
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| Birth Date
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To register your EE SIM and Mobile Number, as required under the SIM Registration Act.
Your Birth Date will now be included as part of your information in our account records, and will be used by us as a security measure to validate your identity whenever you initiate an after-sales request.
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| Nationality (for Foreign Nationals only)
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If you are a foreign national, the following additional personal data will be collected from you, as required under the SIM Registration Act:
1. For Tourists
2. For Other Types of Visas
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| Sex
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To register your EE SIM and Mobile Number, as required under the SIM Registration Act.
Your Gender will now be included as part of your information in our account records.
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| Present or Official Residence Address in the Philippines |
To register your EE SIM and Mobile Number, as required under the SIM Registration Act. Your address will be matched against the Government-Issued ID that you submit, in order to reasonably verify your identity.
In the event that the Address you submit through the SIM Registration Form does not match the information we have in our account records, you will be required to submit proof of billing. Please expect a call-out from us to validate your information.
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| Type of Government ID Submitted with the Government ID Number (for Philippine Nationals only) |
To register your EE SIM and Mobile Number, as required under the SIM Registration Act.
Depending on the type of Government-issued ID that you submit, you may inadvertently provide SMART with other personal data that are not required by RA 11934 (for example, the PhilSys ID includes information on your blood type and place of birth). SMART will not use said personal data as part of your SIM registration record
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| Active Email Address
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To update your information in out account records so that we may send your Electronic Statements of Accounts (eSOA), and other urgent network and service advisories.
The email address you submit will be included in our account records.
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| Alternative Contact Numbers (i.e., Residence and Office Landline Number/s, and other alternative Mobile Number/s) |
Alternative contact number/s will be used for updating your records with us and to contact you for any delivery, account, and billing-related concerns.
The alternative contact numbers you submit will be included in our account records.
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SMART shall retain your Personal Data throughout the duration of your Enterprise Extension subscription, and until ten (10) years after your subscription is terminated or your SIM deactivated. Only the updated and validated information will be stored in our account records; any previously submitted information and documents will be deleted
Why is your personal data shared
Your Personal Data will be processed and stored in systems and databases provided by Salesforce.com (“Salesforce”).
We have also engaged the professional services of:
(1) Capgemini Philippines Corp. (“CapGemini”), to whom we have outsourced the operations of the EE SIM Registration process. On our behalf, CapGemini performs activities such as updating your information in our account records; and
(2) Infocom Technologies Inc. (“Infocom”), to whom we have outsourced the manual validation of the Personal Data you submit through the EE SIM Registration and Subscriber Information Update Forms. On our behalf, Infocom will:
In case of discrepancies, an authorized Infocom agent will reach out to you to perform further verification
Salesforce, CapGemini, and Infocom (collectively, our “Service Providers”) may only process your Personal Data in connection with the above purposes for which they have been engaged. When your Personal Data is shared with them, we ensure that it is done on a confidential basis, through secure channels, and in compliance with applicable privacy laws and regulations. Only personnel with a need-to-know will have access to your Personal Data
How is your data protected
The integrity, confidentiality, and security of your Personal Data is important to us. This is why we strictly enforce this Privacy Notice and have implemented technical, organizational, and physical security measures that are designed to protect your information from unauthorized or fraudulent access, alteration, disclosure, misuse, and other unlawful activities. Your Personal Data is also protected from other natural and human dangers.
We likewise require all our Service Providers to implement the same security measures.
Your rights and choices
The Data Privacy Act gives you certain rights to your personal data. Subject to exceptions under the law, you are entitled to request:
Depending on the circumstances, such as when we process your Personal Data based on your consent, you may also have the right to object to the processing thereof. To exercise any of your data privacy rights, you may contact our Data Privacy Officer through:
SMART COMMUNICATIONS, INC.
DATA PRIVACY OFFICE
Address: 6799 Ayala Ave., Makati City, 1226, Philippines
dataprivacyoffice@smart.com.ph
If you believe that your data privacy rights have been violated in the processing of your EE SIM registration, we encourage you to contact the Company’s Data Privacy Officer to seek resolution of your complaint. Your rights hereunder are in addition to your rights under the Data Privacy Act of the Philippines. You also have the right to go directly to the National Privacy Commission or to make a claim against SMART before a competent court.
