This Privacy Notice outlines how Your Personal Data is collected, managed and Processed by Us. We are committed to handle Your Personal Data in an appropriate and lawful manner. This Policy sets out the minimum requirements for ensuring that the Personal Data collected from You is used, retained and disclosed in a secure and compliant manner.
Interpretation and Definitions
In this policy, unless the context otherwise requires, the following terms shall have the meaning assigned to them here in after;
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application/ Platform means the software program provided by the Company downloaded by You on any electronic device, named “SmartBenefits app”.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Smart PFM Private Limited, having its Office at 3rd Floor, 104-C, DHA Phase 2 Extension, Karachi.
Cookies are small files that are placed on Your computer, mobile device smartphone, tablet/ phablet or any other device by a website, containing the details of Your browsing history on that website among its many uses; the cookies help the application / website to save and remember any preferences that may have been set while the User was browsing the website.
Country refers to: Pakistan
Device means any device that can access the Service such as a computer, a cell phone, a digital tablet workstation, terminal, handheld PC, personal digital assistant or any other hardware where software can be installed that would allow End User to access the services as provided by the Company.
Personal Data means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with Us or identifiable individual, is capable of identifying such person including, but not limited to:
1 – password;
2 – financial information such as Bank account or credit card or debit card or other payment instrument details;
3 – physical, physiological and mental health condition;
4 – sexual orientation;
5 – medical records and history;
6 – biometric information;
7- any detail relating to the above clauses as provided to Us for providing service; and
8 – any of the information received by Us for processing or storage under lawful contract or otherwise:
Provided that, any information that is freely available or accessible in public domain or furnished under any law for the time being in force shall not be regarded as personal information for the purposes of this policy.
Service refers to the Application or the Website or both.
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 analysing how the Service is used.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
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 Smart Benefits website, accessible from https://smartbenefits.pk
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
First name and last name
Account creation date (joining date)
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (IP address), browser type, browser version, the pages of our Service that You visit, the time and
date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and 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.
- 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).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage 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.
For 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.
To contact You: 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 provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
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 personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will 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.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The Company implements appropriate security measures designed to prevent unlawful or unauthorized Processing of Your Personal Data and accidental loss of or damage to Personal Data. We maintain written security management policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Data. These policies and procedures assign specific data security responsibilities and accountabilities to specific individuals, include a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguard your Personal Data. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.
Rights to Access, or Delete Your Information
Users can access individual profile information by logging in to your SmartBenefits employee app
Users can reach out to email@example.com for data deletion request, however this shall be subject to applicable laws & regulations and the Company’s data retention policy, as may be amended from time to time.
Disclaimer of liability
We shall not be responsible in any manner for the authenticity of the Information supplied by the User to Us or Our Affiliates or Third Party Service Providers, as the case may be. If a User provides any Information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or We have reasonable grounds to suspect that such Information is untrue, inaccurate, not current or incomplete, We have the right to suspend or terminate such User’s account at Our sole discretion.
Data Protection Officer (Grievance Officer)
Any questions, discrepancies, and grievances of the provider of information with respect to processing of Personal Data may be made to the Company’s Data Protection Officer (Grievance Officer). The Grievance Officer shall redress the grievances of the provider of information expeditiously and in any event within a period of one month from the receipt of grievances.
In case of any queries regarding the content, interpretation, implications of this Policy, the provider of information may contact the Grievance Officer. Notwithstanding the above, We reserve the right to decline to process any such request which may jeopardize the security and confidentiality of the Personal Data of others, as well as requests which are impractical or not made in good faith, or the circumstances as provided for under the law permitting the Company to refuse such request(s).
The name and contact details of the Grievance Officer are provided below:
Name: Sameed Zaidi
Address: 3rd Floor, 104-C, DHA Phase 2 Extension, Karachi
Email Address: firstname.lastname@example.org
Links to Other Websites
We have no control over and We assume no responsibility for the content, privacy policies or practices of any third party sites or services and the Use of, or reliance on any such links and the content thereon provided shall be at your sole risk.
Amendments to Policy
The Company reserves the right to change, modify, add, or remove portions of this Policy at any time for any reason at its absolute and sole discretion. You can access the latest version of this Policy at any given time on the Platform and it shall be your responsibility to stay updated on any changes to this Policy. Once posted, those changes are effective immediately, unless stated otherwise. Your visit on the Platform is deemed to be your acceptance for the terms and conditions and practices described in this Policy and in case you disapprove the terms and conditions then you should immediately cease to use the Platform.
- By email: email@example.com