Privacy Policy

Your privacy is important to us and we take it very seriously.  The privacy policy exists to keep you informed as it is incorporated into and made a part of the Terms of Use, about  how we collect, use, disclose, store/retain, and/or process data, including your personal data during the course of providing the Services or access to the Platform to You.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Smile Network, accessible from or


This Privacy Policy does not describe what third parties might do with Your Data. We are not responsible for any of the data collected by any such third party.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

Personal Data means any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly, indirectly, and certainly identify an individual.

1 During the course of your use of the Platform and the provision of the Services, we may collect Personal Data from you, which includes but is not limited to:

(a) identity data, such as your name, gender, profile picture, and date of birth;

(b) contact data, such as billing address, delivery address, email address, and phone numbers;

(c) account data, such as bank account and payment details;

(d) technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, and other information and technology on the devices you use to access the Platform;

(e) profile data, such as your username and password,

(f) usage data, such as information on how you use the Platform, products, and Services or view any content on the Platform;

(h) location data, biometric data; and

(j) marketing and communications data, such as your preferences in receiving marketing from us and/or third parties and your communication preferences.

2) During the course of your use of the Platform and the provision of the Services, you expressly consent to the transfer of your Personal Data from third parties to the Company for the purposes set out in this Privacy Policy or any other terms.

3) Your Personal Data must be accurate and not misleading. We shall have the right to request for documentation to verify the Personal Data provided by you as part of our user verification processes.

4) We will only be able to collect your Personal Data if you voluntarily submit the Personal Data to us or as otherwise provided for under this Privacy Policy. Unfortunately, if you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with the Services or access to the Platform.

Tracking Technologies and Cookies

1) When you visit the Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website. This data may include:

(a) your computer or device’s IP address;

(b) browser type;

(c) webpage you were visiting before you came to the Platform;

(d) the pages within the Platform which you visit; and

(e) the time spent on those pages, items and data searched for on the Platform, access times and dates, and other statistics.

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

2) Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  •   To facilitate, provide and maintain our Service, including to monitor the usage of our Service or access to the Platform. To improve the efficiency and operation of the Platform and/or Services.
  • To manage and administer Your Account and Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To notify and provide You with updates, news, special offers and general information about services and events which we offer or enquired about unless You have opted not to receive such information.
  • To respond to and manage to Your queries, feedback, claims, disputes, troubleshoot problems, or product and customer service requests, whether directly or through outsourced customer service agents;[RHS1] 
  • For and in the performance of a contract, the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share your information with Our Service Providers, Business Transfers, Business Partners and Affiliates which include our parent company and any subsidiaries, joint venture partners, or other companies controlled by us or under common control with us.


We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitation or requests. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

We may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, to investigate or remedy potential or actual violations of our policies, to protect the rights, property, and safety of others, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests, which are applicable usually in exceptional circumstances.

Transfer of Your Personal Data

We may share, transfer, disclose, and/or permit the sharing of your Personal Data with third parties and our affiliates to facilitate your use of the Services, completing a transaction with you, managing your account and our relationship with you, fraud protection and credit risk reduction, marketing, and fulfilling any legal or regulatory requirements and requests as deemed necessary by us.

In sharing your Personal Data with them, we endeavor to ensure that the third parties and our affiliates keep your Personal Data secure from unauthorized access, collection, use, disclosure, processing, or similar risks and that your Personal Data be retained only for as long as needed in order to achieve the above mentioned purposes.

Your consent to this Privacy Policy followed by Your submission of such information represents Your consent to such transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

We may transfer or permit the transfer of your Personal Data outside of Your country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction or for any of the purposes set out in this Privacy Policy.

Retention of Personal Data

The Company shall only retainYour Personal Data for as long as is necessary or either is required of us by law or is relevant for the purposes for which it was collected set out in this Privacy Policy. We may also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

We shall cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected and is no longer necessary for any legal or business purpose.

Security and Disclosure of Your Personal Data

We use industry-accepted best practices and reasonable steps to safeguard your Personal Data, You acknowledge and agree that the Company has the right to disclose your Personal Data to any legal, regulatory, governmental, tax, law enforcement or other authorities, or the relevant right owners, if the Company has reasonable grounds to believe that the disclosure of your Personal Data is necessary for the purpose of meeting any obligations, requirements, or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, investigation, and/or request of any nature made by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against the Company for the disclosure of your Personal Data in these circumstances.

If you believe that your privacy has been breached by the Company, please contact us immediately. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely or 100% secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot also guarantee its absolute security.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from anyone under 18 years of age. You hereby confirm and warrant that you are above the age of minority and you are capable of understanding and accepting the terms of this Privacy Policy.


The Company shall not be responsible for any unauthorized use of the Services on the Platform by yourself, users who act on your behalf, or any unauthorized users. It is your responsibility to make your own informed decisions about the use of the Services on the Platform and take the necessary steps to prevent any misuse of the Services on the Platform.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Privacy Policy Updates

We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be posted on this page and notified to you, whereupon your consent to said changes, continued use of the Services or access to the Platform. Please check back frequently to see any updates or changes to this Privacy Policy.

Contact Us

If you have any questions about our Privacy Policy, You can contact us by email: info -at-

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