Smart Axiata Co. Ltd. ("Smart", "we", "our" or "us") values the trust you have in us.
This Privacy Policy applies to our Application titled "Pleng" ("Application") and will be of general interest to you and other internet user(s) who use the online Application "Pleng" for download, access or use of our streaming services or to participate in contests and / or sweepstakes organised and managed by us. The information that we collect would be on account of:-
(i) User voluntarily providing information to us by means of registering or logging into our services either through your personal email id's or via social accounts or otherwise (ii) information of the users that is automatically tracked as per his / her navigation in and around the Application.
By use of the Application, you expressly consent to our use and disclosure of your personal information you provide (including any changes thereto), for any service that we offer, provided the same is in accordance with this Privacy Policy.
This Privacy Policy will provide detailed information on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose or transfer it to others and how we keep it secure.
Please note that our privacy policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically.
This Privacy Policy is incorporated into and subject to the Terms of Use. Capitalized terms that are not defined herein shall bear the same meaning as assigned therein.
The Application may have links to third party website and / or services. Upon clicking such link you may be directed to a third party website. Please note that this Policy does not apply to such third-party websites and / or services.
Smart respects the privacy of End Users of the Application and is committed to reasonably protect it in all respects.
  1. What information is collected about users and members?
    2. Every time you use the Application either through computer, mobile device or other internet connected device or technology the Application either directly or through third party tools uses cookies and collects from you ("individual", "person" or "entity") and stores "Personally Identifiable Information" and / or "Non Personally Identifiable Information".
    In order to avail our services, End Users are required to provide us with certain Personally Identifiable Information (PII) either for registration to create an account with us or for updating their existing account information with us or sign up for subscription or use certain features or access or download content, purchase items or enter into promotions, refer others to the Application, interact with Smart or the Application via third party application or social media sites, request customer support or otherwise communicate with Smart or Smart's business partner's, Smart may collect information that relates to you, including your (i) name and surname, (ii) e-mail, (iii) home address, (iv) telephone number or mobile phone number, (v) credit or debit card details, (vi) sex (vii) age (viii) gender (ix) date of birth, (x) password (xi) occupation (xii) interest and the likes etc. (xiii) geographic location / pin code, (xiv) demographic information, (xv) photos, (xvi) videos, (xvii) social media account details (xviii) advertising identifier of your phone and other information from your device.
    The information that we collect about you while you are using the Application falls into the following two categories.
  2. USER PROVIDED INFORMATION:-
    3. We may collect and store information, personal or otherwise, that you voluntarily supply either while you are using the Application or in responding via email in connection with a feature provided in the Application. Such information may include demographic information that you electronically submit when you sign up for access to certain features in the Application, information (such as your name or email address or mobile number) that you electronically submit when you register for surveys or contests in the Application, information that you post on message boards in the Application, and information contained in search requests or questions that you submit to the Application. If you decline to supply or provide us with certain information while using the Application, you may not be able to use or participate in some or all of the features offered through the Application. Smart hereby notifies that an End User(s) PII that is freely available or accessible via a public domain including any comments, messages, blogs, scribbles etc. posted/ uploaded/ conveyed/ communicated by End User(s) in the End User contributions sections of the Application shall neither be treated as sensitive information nor shall be considered Personally Identifiable Information subject to this Privacy Policy.
  3. INFORMATION AUTOMATICALLY TRACKED WHILE NAVIGATION:-
    1. Cookies information
      2. When you visit the Application, we may either directly or through third party tools send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and assigns to it a random number as a Unique Identification (User ID) to track User(s) browsing behavioural and understand User's individual interests using the identified computer/ mobile device/ internet enabled device. The use of cookies enables Smart to provide User(s) with relevant advertisements or other offers. Parts of the Application may not work as expected without use of the cookies, hence by ignoring or closing the pop up message appearing at the launch of the Application meant for obtaining express consent User(s) are consenting to the use of cookies.
      Smart hereby informs you that unless you voluntarily identify yourself (through registration whether for logging in or subscribing to Smart Services) Smart may not be able to identify you despite the use of cookies. The cookie cannot read any data from your hard drive, the only information that a cookie passes on to Smart's server's is the information that you voluntarily supply. Smart uses both session cookies and persistent cookies.
      A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Application. Persistent cookies can be removed by following your browser help file directions.
      A session cookie is temporary and disappears after you close your browser. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Application may not function properly.
      In addition, our advertising partners may also assign their own cookies, which may get triggered if you click on their advertisement, for collecting and processing information for the purpose of tracking online behavioural advertising, end user tracking or cross device linking that could be stored either on in-house server or a third party server, a process which is beyond the control of Smart. The use and collection of your information by these third party advertisers and ad servers is governed by the relevant third party's Privacy Policy and is not covered by our Privacy Policy and we shall not be responsible for such third party's acts / use of such information. Indeed, the privacy policy of these third party advertisers and ad servers may be different from our Privacy Policy.
    2. Log file information:-
      3. When you use the Application, Smart servers automatically record certain information that your Application sends whenever you visit any application. These server logs may include information such as your request, Internet Protocol ("IP") address, devise name, devise address, devise operating system, browser type, version, internet connection speed, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request and one or more cookies that may uniquely identify your device including browser, your location, IP address, device name, devices serial number or unique identification number etc.
    3. Clear / Transparent GIFs information:-
      4. When you use the Application, we may employ "clear GIFs" (Web Beacons) which are used to track the online usage patterns of our users / members anonymously. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients.
      This information is used by Smart to inter alia deliver our online pages to User(s) upon request, to tailor the Application to suit User(s) interest, measure traffic within the Application, to improve the Application quality, functionality and interactivity and let advertisers know the geographic locations from where the User(s) are accessing the Application.
    4. Information that is received by us from other sources:-
      5. We may also obtain information about User(s) from other sources and combine that with information we collect through the Application. For example, if User(s) creates an account on the Application through a third party social media site, we will have access to certain additional information from that site, such as your friend list, "likes" that you put on the social media sites, comments that you have shared, groups and location, depending on the access granted by User(s) on their respective social media and entertainment site or any interactive service. Additionally, we may obtain information about User(s) through another User's use of third party application or social media site or any interactive service in which such other User(s) participates in, being the connection of such other User(s).
      Depending on User(s) integration of his account on the Application with third party applications and sites Smart may receive similar related information about User(s) including User(s) interactions on such third party applications and sites and information about publicly available activity on such third party applications and sites.
      We may also receive additional information from our partners and service providers (including for example business partners, analytics vendors, advertising networks and search engine providers) which we use to improve your experience, to suit User(s) interest, measure traffic, to improve the Application quality, functionality and interactivity and display advertisements of your interest.
    5. Demographic and purchase information:-
      6. We may also obtain information from google analytics, among others, and track your online browsing behaviour and also obtain information regarding your demographic and other information, this enables us to send you more target based communication and promotional offers of your interest. Such reports if any as may be received by us are anonymous and cannot be associated with any User or such User(s) Personally Identifiable Information unless the same is expressly shared by User(s) or granted access to such User(s) information. Please note that it is the sole discretion of the User(s) to opt out of such Google Analytics and customise Google Settings pertaining to advertisements using the Ad settings options provided by Google.
    6. E-mail Communications:-
      7. To make e-mails more useful and interesting User(s) may receive a confirmation when they open e-mail from us, if their computer supports such capabilities. We also compare our customer list with the lists received from other associate/ affiliate companies, in an effort to avoid sending unnecessary messages to User(s). If you do not want to receive e-mail or other mail from us, please adjust your Customer Communication Preferences.
    7. Links to Third Party sites/ Ad-servers:-
      8. As already mentioned herein, Smart may have links to third party website and / or services. Such third party sites are governed by their respective privacy policies, which are beyond the control of Smart. We may use Third Party advertising companies to serve ads when you visit the Application. Such companies may also obtain and use information (PII or Non - PII) about your visits to the Application and/ or other websites in order to provide advertisements about goods and services of User(s) interest to which Smart has no control over. Smart by itself does not indulge in providing information (PII or Non-PII) to third party websites / advertisers/ ad – servers without User(s) consents.
  4. How we use the information collected?
    5. INFORMATION SHARING / DISCLOSURE
    Smart may share User(s) sensitive and Personal Information/ Non Personal Information with any third party without obtaining the prior consent of the User(s), in good faith and belief that such disclosure is reasonably required, only in the following instances:-
    1. when it is called upon do so / required do so by virtue of applicable law or called upon to disclose under the direction of any court or governmental agency or authority for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences.
    2. Subject to the same terms and conditions and applicable privacy and data protection laws, Smart may share User(s) information within its group companies and officers and employees of such group companies for the purpose of processing personal information for and on its behalf. We require that these parties agree to process such information in compliance with our Privacy Policy, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures.
    3. Smart may share anonymous aggregated statistical information on traffic driven to the Application with advertisers solely for the purpose of understanding Smart's audience and confirm the value of advertising on the Application.
    4. Smart may share information regarding User(s) usage of the Application with third party social websites and populate your social wall, however User(s) always have the option to opt out or change the User(s) settings to allow or disallow what information User(s) desires to show on its wall or share or not to share information with other User(s) of the social websites.
    5. We do share Non-Personally-Identifiable Information (such as anonymous User usage data, referring / exit pages and URLs, platform types, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Application.
    6. Smart also reserve the right to disclose Personally Identifiable Information and/or Non-Personally-Identifiable Information that Smart believes, in good faith, is appropriate or necessary to enforce our 'terms and conditions of use', take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Application, and to protect the rights, property, or personal safety of Smart, our users / members or others.
  5. INFORMATION USED FOR OTHER PURPOSES:-
    6. If you submit Personally Identifiable Information to us through the Application, we may use your personal information to operate, maintain and provide to you the features and functionality of the Application.
    Any and all information, so collected, may be used by Smart primarily to maintain and protect User information. It may be subsequently used to analyse and improve Smart services and / or for developing new services, if any.
    Smart may, without any additional express consent, use the email address or phone / mobile number or such other Personally Identifiable Information for:-
    (a) sending commercial or marketing messages giving User(s) with an option to either subscribe or unsubscribe (where feasible);
    (b) non-marketing or administrative purposes (including notifying User of any major changes to the Application, any change in the usage plan, etc.
    Any personal information or video content that you voluntarily disclose online (on discussion boards, in messages and chat areas, within your public profile page, etc.) becomes publicly available and can be collected, seen and used by others besides us. We cannot be and are not responsible for any unauthorized third party use of such information. Your account name (not your email address) is displayed to other users / members when you upload videos or send messages through the Application and other users / members can contact you through messages and comments. Any videos that you submit to the Application may be redistributed through the Internet and other media channels, and may be viewed by the general public. We do not use your email address or other Personally Identifiable Information to send commercial or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. We reserve the right to use and to disclose to third parties all of the information that we collect online about you and other visitors in any way and for any purpose, with one important exception viz. we will not use the information that we collect online from you while you are using the Application, nor will we authorize third parties to use such information, to mail or email promotional offers directly to you unless you have specifically informed us that you would like to receive promotional offers from us and/or from third parties. If you choose to receive these promotional offers, then your information may be used for direct mail or email marketing. We use both your Personally Identifiable Information and certain Non-Personally-Identifiable Information (such as anonymous user usage data, cookies, IP addresses, browser type, click stream data, etc.) to improve the quality and design of the Application and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user / member preferences and trends. We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Application; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our marketing campaigns; (d) monitor aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) track your entries, submissions, and status in promotions, and contests. We may also make some content, products and services available through our Application through cooperative relationships with third party providers, where the brands of our provider partner appear on the Application in connection with such content, products and/or services. We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly; in which cases the privacy policy of the provider partner may apply to the provider partner's use of your information. The privacy policy of the provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.
    We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes. Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or our Application is acquired by another company, information about our visitors may be among the transferred assets.
  6. ACCESSING AND UPDATING PERSONAL INFORMATION:-
    7. Access / Choice for update:-
    You may at any time modify your registration information by clicking on the "Edit Profile" subsection of the "My Account" area of the Application, so long as you continue to provide us with certain information required to maintain your subscription (such as a valid email address). Also, marketing e-mails from will come with instructions for un-subscribing from our email mailing list.
    Right of erasure/ to be forgotten:- User(s) may exercise its right and request for deleting personal/ non-personal information that is obtained / acquired by Smart on account of User(s) interaction, whatsoever, with the Application.
    Please be informed that requesting for being forgotten or for deletion of your record is not like unsubscribing or opting out from specific emails or deactivating certain settings on google or other social media websites or interactive pages etc. and such erasure / deletion is complete and an irreversible process. Upon such erasure / deletion we will lose all records (barring archival or backups) of User(s) having ever been on the Application or our servers or systems, including any previous instruction you have given to Smart and opting out of specific email types. If you re-join our systems by voluntarily providing your personal information, you will appear to us as a completely new data subject. This does not affect your rights in any way.
    If User(s) wishes to verify, correct or update or delete any of your personal information collected by Smart by virtue of your use of the Application, you may write to us at the following email address:- [email protected]
    For the said purpose we may additionally require User(s) to identify themselves and the information requested to be accessed, corrected or removed before processing any such User(s) request. We may delete any personal information that is publicly available and are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. We reserve the right to decline any such request for want of proper identification required to act upon User(s) request. We may also decline requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of another User(s) or would be extremely impractical (for instance, requests concerning information residing on backups or archival records) or for which access is not otherwise required.
  7. Our Commitment to Children's Privacy:-
    8. The Application is NOT directed to or INTENTED for individuals under the age of 18 (eighteen). An individual less than 18 (eighteen) years of age SHOULD not register to use the Application but if you are above 13 (thirteen) years of age or older but below 18 (eighteen) years, you may be granted access by providing either of your parent's Email IDs and an Email will be sent informing the parent that their ward has registered himself / herself to use the Smart services through the Application. If you are a parent of a child under the age of 18 (eighteen) and you have questions about our Application or Privacy Policy, please feel free to contact the Privacy Coordinator. Parent's of such underage individuals will be legally bound by any Acts / Deeds / Violation of Terms and Conditions of Use, Privacy Policy and the end user license agreement.
    Please be informed that we do not knowingly collect personal information from anyone under the age of 13 years. If at any given point of time, we determine that the information collected pertains to a User(s) below 13 years of age we reserve the right to refrain from using or maintaining.
  8. Our Assurance & Commitment towards Data Security:-
    9. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to and you do so at your own risk. Once we receive your transmission of information, makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If Smart learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Smart may post a notice on the Application if a security breach occurs. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify the Privacy Coordinator at the below mentioned email id [email protected]
    Smart is registered in Cambodia.
    Smart will, at any point of time, be complying with the legal provisions, as applicable in Cambodia from time to time.
    Changes to your personal information on site notification of changes:-
    Smart reserve the right at any time to change the terms of this policy; change the services provided on the Application, including eliminating or modifying any content on or feature of the Application; or change / charge any fees or charges for use of the services available on the Application.
  9. Conflict Resolution:-
    10. Smart is committed to resolving disputes as soon as feasible and shall endeavor to resolve all disputes brought to our notice in keeping with the mechanism prescribed.
    QUESTIONS / GRIEVANCE CELL:-
    In the event you have any grievance relating to the processing of User(s) information provided by you, you may contact our Grievance Officer and Grievance Redressal Officer Mr. Mc. Neil Jesse at [email protected] at the following address:-Smart Axiata Co. Ltd. No. 464A, Preah Monivong Blvd, Sangkat Tonle Bassac, Khan Chamkarmorn, Phnom Penh 12301, Cambodia.
    We request you to please provide the following information in your complaint:-
    1. Identification of the information provided by you to enable us to verify the complainant.
    2. Clear statement as to whether the information sought to be accessed or updated is your personal information or non-personal information.
    3. Your correct address, telephone number or email address.
    4. A statement that you have approached us with the notice for records in good faith and has reason to be believe that your information has been processed incorrectly or disclosed without authorisation, as the case may be.
    5. A statement that the information provided by you in the notice is accurate and that the information being complained about belongs to you.
This Privacy Policy is applicable to you.
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