Introduction

Thank you for taking the time to review Smile’s Privacy Policy. At times, Smile will collect certain personal information about customers and visitors to websites hosted by Smile. Such information will include both identifiable personal data, as well as non-identifiable personal information. Identifiable personal information will be collected when you sign a contract for service with Smile, or use the Smile website for a transaction or subscription service. Non-identifiable information is gathered automatically when you visit the Smile website or those websites hosted by Smile, and stored for use in Smile’s system.

The purpose of this privacy policy is to explain to customers what types of information Smile will collect and how that information is used. In most cases, Smile collects this information to ensure network integrity and that Smile continues to provide you with the most relevant content and best possible service that suits your needs. In some cases, Smile is required by law to collect personal information about customers. Except where the law requires otherwise, Smile undertakes to protect the confidentiality of such data.

Confidentiality

Smile respects customer privacy and the privacy of those accessing Smile’s website, or those websites hosted by Smile. Smile undertakes to protect the confidentiality of Smile customers and users including all personal information supplied in the course of contracting with Smile for services. Smile undertakes not to sell your personal information to third parties for commercial or marketing purposes.

Collection of Personal Data

Smile collects personal data about Smile’s users when you visit a website hosted by Smile; apply for a service subscription; respond to a customer questionnaire; participate in a competition or promotion and through the use of cookie technology. A cookie is a data file that sits on your computer hardisk. The cookie is placed there by a remote web server that you have visited using a browser like Netscape or Internet Explorer. It is used to uniquely identify you during web interactions with a website and contains data parameters that allow the remote HTML server to keep a record of who you are, and what actions you take at the remote web site. You have the option to disable the cookie function in your browser, but will be restricted from accessing many sites as a result. Smile may also combine information about you with information Smile obtains from Smile business partners or affiliates.

Use of Personal Data

Smile may on occasion use your personal information to contact you about promotional offers; advise you of matters relevant to service provision and in some cases, solicit your feedback. However, Smile will provide you with an option within every communication to opt out of receiving any communications of this nature.

Smile collects and shares aggregated user data with business partners, sponsors or other third parties for the purposes of developing content and ensuring relevant advertising and content, such user data will never be used to identify individual users. These business partners and affiliated companies do not have any independent right to share this information.

Smile may log the websites you visit; collect IP addresses and information about your operating system and the type of browser you use for the purposes of network/system administration; to report aggregate information to Smile’s advertisers, and to audit the use of Smile’s site. This data however, will not be used to identify individual users who will at all times remain anonymous.

Any information Smile collects from you through correspondence with Smile, whether via e-mail, telephonically or by written letter, will only be used to address the matters within that correspondence. If this requires referring such correspondence within Smile or to a third party to ensure customer service, your personal information will only be disclosed to the point necessary to address your query or concerns, and will otherwise be kept confidential.

Public Space (Bulletin Boards, Chat Rooms and Third-Party Sites)

Any information that customers disclose in a public space, including on any bulletin board, chat room or any site Smile may host for you, is available to anyone else who visits that space. Smile cannot safeguard any information you disclose there.

Site Linking

Smile’s websites contain links to sites that belong to third parties unrelated to Smile. Smile cannot be held responsible for any use of your personal information arising from you disclosing personal such information on third party sites. Smile cannot protect any information you may disclose on these sites and recommends that you review the privacy policy statements of those sites you visit.

Minors

Smile will not enter into a service subscription contract with a minor unless such minor has explicit written consent from a parent or guardian to do so. Smile undertakes not to contact minors about promotional offers or for marketing purposes without a parental consent.

Reservation of Rights

Smile reserves the right to disclose information about customers where required in good faith, to do so by law or to exercise Smile’s legal rights or to defend Smile against legal claims.

Smile further reserves the right to share information with law enforcement to investigate or prevent illegal activities being committed over Smile’s network.

Smile reserves its rights to disclose your personal information where you have given Smile explicit legal written consent to do so.

Smile reserves the right to monitor user and network traffic for site security purposes and to prevent any unauthorized attempts to tamper with Smile’s site or cause damage to Smile’s property.

Smile reserves the right to make changes to this privacy policy or update it. Where a major change is made, customers will be informed by e-mail notification or through a notice on Smile’s website. Customers and site visitors bear the responsibility to ensure that they have read the changes or updates as the case may be.