1. Introduction

Samart Corporation Plc (“Samart” or “us” or “we”) provides this Privacy Notice (the “Notice”) to inform you of our practices regarding the collection, use and disclosure of information we receive from users of the Samart website, any other Samart sites that link to this Notice, other Samart events such as trade shows or sponsored events (collectively, the “Site”). Except where explicitly provided otherwise herein, this Notice applies to information provided or collected through the Site, and other information collected by Samart offline. Any information collected from you from the use of one of our applications will be subject to a separate privacy notice. Note that Samart’s applicable terms of service for our services may contain additional notices and terms that apply to our collection and use of data and metadata in connection with your use of those services. This Notice may be updated from time to time. We will notify you of any material changes by posting the new Notice on the Site. You are advised to consult this policy regularly for any changes.

2. Information We Collect

Samart may collect the following categories of information, some of which you may voluntarily provide, from your use of the Site:

• Identification Data, including your name, title, and job title.
• Contact Data, including your phone number, address, and email address.
• Cookie and Device Data, including information about your visit of our website, IP address, device identifier, browser type and version, operating system and network, location and time zone setting, and other similar tracking technology as further explained below.
• Event Registration Data, including Identification Data, Contact Data, and other information you provide to us when you access various Samart content, such as whitepapers, videos, or other research materials.
• Job Applicant Data, including Identification Data and Contact Data, resume and other data provided by you or third parties (e.g. recruiters) on our website in connection with job openings.
• Third Party Information. We may also collect these same categories of information through the use of our third-party marketing and content syndication vendors.

3. How We Use Your Information

We take your privacy very seriously and will only use and disclose this information for the business and commercial purposes described in this Notice. How we use your information will vary depending on the type of data as described below:

• Addressing customer inquiries – we use Identification Data, and Contact Data to address customer inquiries so that you may receive a response from us when you contact us.
• Sending relevant marketing messages and inviting you to events/seminars – we use Identification Data, Contact Data, Cookie and Device Data, and Event Registration Data to communicate with you by way of email alerts and mail to provide you with information about product announcements, and special promotions from Samart or our business partners, to invite you to events that may be of interest to you, or to administer participation in surveys, contests and sweepstakes. You can choose not to receive such marketing communications by clicking on the unsubscribe link in our emails, as further described below.
• Improving our Site – we use Cookie and Device Data to improve the functionality and user-friendliness of our Site. If you fill out a survey or email Samart for support, we may retain that information in order to provide you with support and to improve our Site.
• Keeping our Site and IT systems and processes safe – we use Identification Data, Contact Data, and Cookie and Device data to ensure the security and confidentiality of your data, and to prevent illegal activities, including fraud, which could harm you and us.
• Recruitment – Job Applicant Data is collected and processed for purposes of screening, identifying, and evaluating candidates for positions; and record-keeping related to hiring processes. This processing is necessary in order to take steps at the request of the job applicant in the context of recruitment prior to entering into a contract and may be used as necessary to comply with legal, regulatory, and corporate governance requirements.

You may opt out of receiving promotional communications from Samart by using the unsubscribe link within each email. Although opt-out requests are usually processed immediately, please allow ten (15) business days (Hong Kong Time zone) for a removal request to be processed.

4. How We Disclose Your Information

Samart may disclose your information with other members of our corporate family, or with third parties to provide or improve our services. For example:

• Third Party Service Providers and Partners. We may share your information with third party service providers of products and services integrated with our Site that need to know your information for Site improvement purposes. We may share your information with our affiliates, resellers or other third-party service providers that are working with Samart to perform business-related functions. We may also disclose your information to our third-party partners so they may contact you on our behalf with relevant marketing messages, which you can choose not to receive by clicking on the unsubscribe link in our emails.
• To collect and analyze information regarding your usage of our Site as described in Section 6 below.
• To Comply with Law. We may disclose your information consistent with the law to, for example: (i) comply with a law, regulation, or legal process (including to meet national security or law enforcement requirements); (ii) protect the safety or security of any person, entity or facility; (iii) address potential violations of our Notice; (iv) investigate fraud, security, or technical issues; or (v) protect Samart’s or a third party’s rights or property, our employees, users and the public. We strongly believe that you have a right to know if we are required by law to disclose your information. As such, before we disclose your information in response to a law enforcement request (for example, a subpoena or court order), we will notify you at the email listed in your account, unless (a) we are prohibited from doing so or (b) in emergency cases where notice could create a risk of injury or death, or the case involves potential harm to minors. Furthermore, nothing in this Notice is meant to limit any legal defenses or objections that you may have to a third party, including the government’s, request to disclose your information.
• During a Change to Samart’s Business. We may also disclose your information to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Notice.
• Pseudonymized and Aggregated Data. For data analysis we pseudonymize, aggregate and summarize data that may include some of your data.
• With Consent. We may also disclose your information to third-parties when we have your consent to do so.

5. Your Choices

a. Email Opt-Outs

• You may opt out of receiving promotional communications from Samart by using the unsubscribe link within each email. Although opt-out requests are usually processed immediately, please allow fifteen (15) business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you may continue to receive transactional and product-related messages from us if you use the Samart’s products/services, in which case you can opt-out of these notification messages in your account settings.

b. Personalized Advertisements

• You may be able to opt out of receiving certain personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt out directly from providers who participate in those programs. Samart does not control or operate these tools or the choices that advertisers and others provide through these tools.

6. Use of Cookies by Samart

Like most providers of online services, we use cookies and other tools to collect and analyze information regarding your usage of our Site. Cookies are small data files that we store on your computer or device. For details, see online cookies information.

a. How We Use Cookies

We use “session” cookies to monitor aggregate usage and web traffic information on our Site. Session cookies disappear when you log out and close your browser. We also use “persistent” cookies to recognize you when you return to use our Site. Persistent cookies can stay on your computer for a longer period of time than session cookies do. We also use “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Site and how they are interacting with our Site. This helps us to improve the experience on our Site. Finally, we may use other standard technologies, such as clear gifs and local storage to analyze, collect and aggregate data about your use of our Site. We use the data we collect from these tools as described below.

b. Cookies from Third-Parties

We believe it is important for you to know what third-party cookies we use on our Site. Here is a list of the thirdparty cookies that we currently use. As we develop and improve our services, we may use other third parties that are not listed below.

Google Analytics— These cookies allow us to see how you use our Site so that we can improve your experience. We encourage you to read the Google Privacy Policy , If you don’t want data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on.

Google AdWords — These cookies allow our vendors to serve ads based on your past visits to our sites and for remarketing purposes. Google may use this cookie and other tracking technology to show you our ads across the internet. Google permits you to opt out of Google’s use of these cookies by visiting Google’s Ads Settings

Social Media Features — Social media features such as a “like” button may be hosted by a third party. If you use these Features, they may collect your IP address, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our Notice.

c. How to Control Cookies

Most Internet browsers automatically accept cookies, but some browsers may permit you to change your settings or use third-party tools to disable cookies or to prompt you before accepting cookies from the websites you visit. These browsers or other third-party tools may also permit you to delete cookies you already have. Please be aware that some parts of our services may not work for you if you delete or disable cookies.

7. Data Retention

Samart will retain your information, including your Personal Data (as that term is defined by the GDPR), only as long as reasonably necessary to use the Site or as otherwise required for legal compliance purposes.

8. Security

a. Samart’s Responsibilities

• Samart is a security company, and securing your data is important to us. Samart uses commercially reasonable physical, managerial, and technical safeguards to ensure appropriate technical and organizational measures appropriate to the risk of processing your information. For example, we use a combination of firewalls, authentication, physical security, and other safeguards to protect your account and your data. When you enter sensitive information on the Site we encrypt that information while in transit and at rest using secure socket layer technology (SSL). We also perform third-party penetration tests to harden our systems from attack. Samart takes every reasonable effort to implement controls to protect against complex technological threats and other criminal threats, as well as to guard against negligent employees. Because no method of transmission over the Internet or method of electronic storage is 100% secure, we cannot ensure or warrant the security of any information, data or content that Samart receives on your behalf to operate the Samart Site, or that you transmit to Samart. All such receipt or transmission of your information is provided under your own free will and at your own risk. We cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards If Samart learns of a security breach, we will attempt to notify you electronically so that you can take appropriate protective steps. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

b. We Are Not Responsible for Content on Third-Party Websites

• Our Site contains links to other websites. When you click on one of these links, you leave Samart’s website and go elsewhere. Samart does not accept liability for misuse of any information by any website controller to which we may link. We encourage you to read the privacy statements of these linked sites, which may differ from ours. In addition, if you take advantage of an offer from one of our partners, you may be providing information directly to that partner. We encourage you to review the privacy statements of these partners, as we are not responsible for the privacy practices of any partners or linked sites.

9. Users Under 16

Because Samart provides services to an international customer base, in order to comply with both U.S. and E.U legal requirements pertaining to both Chapter 91 of Children’s Online Privacy Protection Act and Article 8 Conditions Applicable to Child’s Consent in relation to information society services of the GDPR Samart does not knowingly collect or store any Personal Data about children under the age of 16.

10. International Data Transfers

Samart is a Thailand-based company with servers housed in the Hong Kong and Singapore. Personal Data collected from users outside the Hong Kong and Singapore is transferred to the Hong Kong and Singapore. If you are using the Samart Site from outside Hong Kong and Singapore your information may be transferred to, stored, and processed in the Hong Kong and Singapore where our servers are located and our databases are operated.

11. Contact Us if You Have Any Questions or Concerns

Please contact our Data Protection Officer at info@Samart.com.