1                    SME GURU PTE. LTD. PRIVACY POLICY

1.1             SME Guru Pte. Ltd. (“SME Guru”, “we”, “our”, “us”, or “owner”), along with our affiliates and subsidiaries, is deeply committed to protecting the privacy and security of your personal information. Our Privacy Policy governs the collection, processing and usage of data in strict compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore. This Privacy Policy applies to the smeguru.ai and smebot.ai websites (collectively, the “Website”) as well as our products and services (the “Solutions”). This Privacy Policy applies to you (“users”, “visitors”, “our customers”, “prospective customers”, “our customers' customers” [both direct and indirect]). We understand the importance of your privacy and are dedicated to ensuring that your information is handled with the utmost care and transparency. The purpose of this Privacy Policy is to explain how we collect, use, and disclose information or data obtained through your use of our Websites and Solutions. We are committed to obtaining explicit consent from you for specific purposes as required by applicable laws and outline the mechanisms we use to obtain, manage, and withdraw explicit consent. We encourage you to take the time to review it carefully, to understand what information we collect, why we collect it, and what we do with it. By using the Website and or the Solutions, you agree to our Privacy Policy. If you do not agree with this Privacy Policy, do not access or use our Solutions or interact with any other aspect of our business. Capitalised terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service. Below, we cover the following topics:

1.1.1.           Who we are

1.1.2.           What information we collect, why and how we use it

1.1.3.           Who we share your information with and why

1.1.4.           How we protect and process your information and data

1.1.5.           How long we store your information for

1.1.6.           How to access and control your information

1.1.7.           Other important information

1.1.8.           How to contact us

1.1.9.           Cookies and tracking notice

1.2.             If you have any questions or suggestions concerning our privacy practices, please email us at hello@smeguru.ai. Please specify the Website and the paragraph(s) you are concerned with in your email. Additionally, should you wish to request data access or deletion, or exercise any other data subject rights, please contact us via email.

2                 WHO WE ARE

2.1            SME Guru provides our customers with online solutions and allow them to improve their interactions with individuals on existing social media, messaging services and platforms. We act as a Solutions provider to our customers, and we collect data on behalf of our customers. This Privacy Policy does not reflect the privacy practices of our customers, and SME Guru is not responsible for our customers’ privacy policies or practices. We do not review, comment upon, or monitor our customers’ privacy policies or their compliance with their respective privacy policies. Nor do we review our customers’ instructions regarding our processing of information to determine whether such instructions are in compliance with or conflict with the terms of our customers’ published privacy policy. If you are a customer of one of our customers and would no longer like to be contacted by them, who uses our Solutions, please contact that respective customer that you interact with directly.

3                  WHAT INFORMATION WE COLLECT, WHY AND HOW WE USE IT

3.1               We collect information in the following ways:

3.2               Information you provide directly to us.

3.2.1         Customer Account Details. To create or update your account and provide the Solutions, we collect information about you, as a customer or end-user of the Solutions, from both you and third-party integrations (e.g., Facebook, Instagram, etc.). This may include ID, full name, email, telephone number, status, company details (if provided), job title, linked pages and accounts, products in use, location, etc.

3.2.2           Financial Information. To process your payments for the Solutions fee or subscription, we require your credit card details, account details and payment information.

3.2.3         Contact Details and Business Data. We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email, or other necessary contact details.

3.2.4         Requests, Messages and Submitted Forms Details. We receive and process your messages, chat, support requests, emails, and information shared via online forms, chatbots, email, or social media accounts. This includes the content of such communications as well as your contact details, if provided. When requesting support, we may also collect additional information such as documentation, screenshots, or other helpful details.

3.2.5       Customer Content. As you use our Solutions, you may import personal data collected from your users, customers, prospective customers, social media and messaging platform contacts (collectively “Subscribers”), or other individuals. We process this data on your behalf and have no direct relationship with your Subscribers. Therefore, you are responsible for ensuring appropriate permissions and legal bases for collecting and processing information about those individuals.

3.3              Information we collect automatically when you visit our Websites (and/or microsite web pages).

3.3.1           We automatically collect certain information to understand how visitors use our Websites. For example, each time you visit, we collect your IP address, browser and computer type, access time, referring page, and pages visited during your session. We also use cookies to track your usage, validate your identity, remember preferences, tailor content, and improve our Websites’ quality.

3.4              Information we get from third parties.

3.4.1          Demographic, Lead, and Interest Data. We may obtain information from external sources, including companies collecting customer data such as demographic and interest information. This may include your job title, employer, and business contact information. We combine this data with existing information to predict preferences and direct relevant marketing offers.

3.4.2          Information about our customers' customers. We may receive personal information about our customers' customers from various sources, including our customers themselves, server operators, relevant databases, and other third parties. This may include telephone numbers and their validity, helping us provide our Solutions effectively.

3.5         Information collected in connection with your usage of our Solutions. We and our Solutions providers may collect information related to your usage of communications services delivered via our Solutions.

3.5.1       Communications Usage Information. This includes details about your communications delivered via our platform, such as time, duration, source, destination, completion status, location, IP address, and volume of usage.

3.5.2          Communications Content. To facilitate communications via our platform, we process the content of messages, calls, emails, and other communication channels used by you, including call recordings recorded via our Solutions.

3.5.3           Device Information.

3.5.3.1        Your Contact Lists and Address Book. With your permission, we may access, and store contact lists or address books maintained on your devices. This information is considered personal data and may be used to facilitate certain services, such as enabling easy calls and facilitating communication services. You have the option to opt out of this access through your device's privacy settings and if you do not, certain features of our Solutions may not be available to you.

3.5.3.2        Mobile Device Camera, Microphone, and Photos. With your permission, we may access the camera, microphone, and photos on your mobile device to enable voice and video calls and messages. You have the option to opt out of this access through your device's privacy settings, and if you do not, certain features of our Solutions may not be available to you.

3.6             Why we collect your information and how we use it depends on which of our Solutions you use, how you use them, and the specific preferences you may have communicated to us.

3.6.1         To deliver our Solutions. We use your information to fulfil our obligations in delivering our Solutions, including agreement and account creation, transaction processing (such as billing), authentication for logins, customer support, and communication about the Solutions. We communicate with you about the Solutions, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, support and administrative messages, and other communications necessary to usage of the Solutions.

3.6.2           To carry out core activities relating to our Solutions. We use your information for important and essential supporting activities such as:

3.6.2.1         Billing and collections, including maintenance of records in the event of a subsequent billing dispute;

3.6.2.2        Preventing fraud, violations of our acceptable use policies, and unlawful activities;

3.6.2.3.       Troubleshooting, quality control, and analytics; and

3.6.2.4        Monitoring the performance of our systems and platform.

3.6.3       To comply with legal requirements. We may be required by applicable laws or regulations to process your data, such as those mandating the retention of communications data.

3.6.4          To protect our legitimate business interests and legal rights. When deemed necessary to safeguard our legal rights, interests, and those of others, we utilise your information for purposes such as legal claims, regulatory compliance, and disclosures related to business transactions such as acquisition, merger or sale of a business.

3.6.5          For Compliance and Safety. We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Solutions; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity

3.6.6          According to your explicit consent. Should we require your information for specific purposes that necessitate consent under applicable law, we will obtain your explicit consent beforehand. This may include scenarios such as:

3.6.6.1.        Testimonials and Case Studies that identify you in your individual capacity.

3.6.6.2.        Sensitive Data such as political opinions, religious beliefs or health information that are required to be processed.

3.6.7         For Research and Development. We analyse user communications to improve our Solutions' reliability, security, and utility. We use data to understand usage patterns and identify areas for enhancement. We and our service providers may use your information to assess the level of interest in, and use of our Solutions, to market, promote, and drive engagement of our Solutions.

3.6.8.         To market, promote, and drive engagement of our Solutions. When you sign up or submit information to us, you consent to receiving promotional communications via email, text messages, phone calls, faxes, and postal mail from SME Guru. We use your data to customise promotional communications aligned with your interests, optimising how we market our Solutions. To perform these functions and others outline in our Privacy Policy, we may combine information from different sources, including personal data and usage details supplemented by data from third parties. In jurisdictions where permitted, you also consent to receive phone calls from us and our affiliates, even if your phone number is listed on "do not call" registries. You are not required to accept promotional communications to use our Solutions. Details on managing your preferences can be found in the "Opt-out of Communications" section under 'How to access and control your information'.

3.7               Detailed information on the processing of Personal Data

3.7.1            Personal Data is collected for the following purposes and using the following services:

3.7.2           Access to third-party accounts

3.7.2.1        This service allows SME Guru to access data from your account on a third-party service, such as Facebook, and perform actions with it as required for our services. We ensure that this access is not activated automatically but requires explicit authorization from you, the user.

3.7.2.2         Facebook account access (Facebook, Inc.)

3.7.2.3       This service enables SME Guru to connect with your account on the Facebook social network, provided by Facebook, Inc. The permissions requested are necessary to facilitate specific functionalities offered by SME Guru's services. These permissions include but are not limited to access to basic profile information, managing pages, and managing advertisements.

3.7.2.4     Permissions asked: About Me; Business Management API; Contact email; Instagram basic; Instagram manage comments; Manage Pages; Managing Page Advertisements; Page Messaging; Pages manage engagement; Pages manage metadata; Pages manage posts; Pages read engagement; Pages User locale; Pages User timezone; Show List of Managed Pages.

3.7.2.5        Place of processing: United States – Privacy Policy. Please note that the processing of data from your Facebook account may occur in the United States. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.2.6       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.3            Analytics

3.7.3.1        The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

3.7.3.2        Google Analytics

3.7.3.3      Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this SME Guru is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of SME Guru, to prepare reports on its activities and share them with other Google services.

3.7.3.4        Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

3.7.3.5        Personal Data processed: Tracker; Usage Data.

3.7.3.6        Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.3.7       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.3.8        Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

3.7.3.9       Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on SME Guru. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

3.7.3.10      Personal Data processed: Tracker; Usage Data.

3.7.3.11      Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.3.12     The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.4           Handling Payments

3.7.4.1        Unless otherwise specified, SME Guru processes any payments by credit card, bank transfer or other means via external payment service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. SME Guru is not involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

3.7.4.2        Stripe (Stripe Technology Europe Ltd)

3.7.4.3        Stripe is a payment service provided by Stripe Technology Europe Ltd.

3.7.4.4        Personal Data processed: email address; first name; last name; payment info.

3.7.4.5        Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.4.6       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.5           Interaction with Live Chat Platforms

3.7.5.1       This type of service allows Users to interact with third-party live chat platforms directly from the pages of SME Guru, in order to contact and be contacted by SME Guru‘s support service.

3.7.5.2       If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

3.7.5.3        Facebook Messenger Customer Chat

3.7.5.4       The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location SME Guru is accessed from,

3.7.5.5        Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

3.7.5.6       Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.5.7       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.6           Hosting and backend infrastructure

3.7.6.1        This type of service has the purpose of hosting Data and files that enable SME Guru to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of SME Guru.

3.7.6.2        Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

3.7.6.3         Google Cloud Storage (Google LLC)

3.7.6.4        Google Cloud Storage is a hosting service provided by Google LLC.

3.7.6.5         Personal Data processed: various types of Data as specified in the privacy policy of the service.

3.7.6.6       Place of processing: United States – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.6.7       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.6.8         Google App Engine

3.7.6.9         Google App Engine is a hosting service provided by Google LLC or by Google Ireland Limited, depending on the location SME Guru is accessed from.

3.7.6.10       Personal Data processed: various types of Data as specified in the privacy policy of the service.

3.7.6.11      Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.6.12     The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.7           Registration and authentication

3.7.7.1        By registering or authenticating, Users allow SME Guru to identify them and give them access to dedicated services.

3.7.7.2        Depending on what is described below, third parties may provide registration and authentication services. In this case, SME Guru will be able to access some Data, stored by these third-party services, for registration or identification purposes.

3.7.7.3       Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

3.7.7.4        Google OAuth (Google Ireland Limited)

3.7.7.5        Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

3.7.7.6        Personal Data processed: various types of Data as specified in the privacy policy of the service.

3.7.7.7        Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.7.8       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.7.9        Facebook Authentication (Facebook Ireland Ltd)

3.7.7.10      Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

3.7.7.11       Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

3.7.7.12      Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.7.13     The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.7.14      Facebook Oauth

3.7.7.15    Facebook Oauth is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location SME Guru is accessed from, and is connected to the Facebook social network.

3.7.7.16      Personal Data processed: Tracker; various types of Data.

3.7.7.17      Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.7.18     The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.8           Contacting the User

3.7.8.1        Mailing list or newsletter (SME Guru)

3.7.8.2        By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning SME Guru. Your email address might also be added to this list as a result of signing up to SME Guru or after making a purchase.

3.7.8.3        Personal Data processed: email address; first name; last name; phone number; Usage Data.

3.7.8.4       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.9           Tag Management

3.7.9.1        This type of service helps the Owner to manage the tags or scripts needed on SME Guru in a centralized fashion.

3.7.9.2        This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

3.7.9.3        Google Tag Manager (Google Ireland Limited)

3.7.9.4        Google Tag Manager is a tag management service provided by Google Ireland Limited.

3.7.9.5        Personal Data processed: Tracker; Usage Data.

3.7.9.6       Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.9.7       The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.10         Advertising

3.7.10.1     This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on SME Guru, possibly based on User interests.

3.7.10.2      This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

3.7.10.3      Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside SME Guru. For more information, please check the privacy policies of the relevant services.

3.7.10.4      In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

3.7.10.5      Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

3.7.10.6      Google Ad Manager (Google Ireland Limited)

3.7.10.7     Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.

3.7.10.8      This service uses the “DoubleClick” Cookie, which tracks use of SME Guru and User behaviour concerning ads, products and services offered.   Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

3.7.10.9      Personal Data processed: Tracker; Usage Data.

3.7.10.10    Place of processing: Ireland – Privacy Policy. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.10.11    The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.10.12    Facebook Lookalike Audience

3.7.10.13    Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location SME Guru is accessed from, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of SME Guru or engagement with relevant content across the Facebook apps and services.

3.7.10.14    On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

3.7.10.15    Personal Data processed: Tracker; Usage Data.

3.7.10.16    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.10.17   The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.11         Remarketing and behavioural targeting

3.7.11.1      This type of service allows SME Guru and its partners to inform, optimize and serve advertising based on past use of SME Guru by the User.

3.7.11.2      This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.

3.7.11.3       Some services offer a remarketing option based on email address lists.

3.7.11.4       In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

3.7.11.5      Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

3.7.11.6      Facebook Custom Audience (Facebook Ireland Ltd)

3.7.11.7     Facebook Custom Audience is a remarketing and behavioural targeting service provided by Facebook Ireland Ltd that connects the activity of SME Guru with the Facebook advertising network. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

3.7.11.8     Personal Data processed: email address; Tracker.

3.7.11.9     Place of processing: Ireland – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.11.10   The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.11.11     Facebook Remarketing (Facebook Ireland Ltd)

3.7.11.12   Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook Ireland Ltd that connects the activity of SME Guru with the Facebook advertising network.

3.7.11.13     Personal Data processed: Tracker; Usage Data.

3.7.11.14    Place of processing: Ireland – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.11.15    The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.11.16    Google Ads Remarketing (Google Ireland Limited)

3.7.11.17   Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of SME Guru with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

3.7.11.18     Personal Data processed: Tracker; Usage Data.

3.7.11.19    Place of processing: Ireland – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.11.20    The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.11.21     LinkedIn Website Retargeting (LinkedIn Corporation)

3.7.11.22    LinkedIn Website Retargeting is a remarketing and behavioural targeting service provided by LinkedIn Corporation that connects the activity of SME Guru with the LinkedIn advertising network.

3.7.11.23     Personal Data processed: Tracker; Usage Data.

3.7.11.24   Place of processing: United States – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.11.25    The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.11.26     Twitter Remarketing (Twitter, Inc.)

3.7.11.27    Twitter Remarketing is a remarketing and behavioural targeting service provided by Twitter, Inc. that connects the activity of SME Guru with the Twitter advertising network.

3.7.11.28    Personal Data processed: Tracker; Usage Data.

3.7.11.29   Place of processing: United States – Privacy Policy – Opt Out. However, SME Guru ensures that such processing complies with the data protection principles outlined in the Personal Data Protection Act 2012 (PDPA) of Singapore.

3.7.11.30   The categories of personal data collected from your third-party accounts may include identifiers, contact information, and any other information necessary for the provision of our services.

3.7.12         Interaction with AI-Human Hybrid Chat Supports

3.7.12.1     This type of service allows User to interact with SME Guru AI-Human Hybrid Chat Supports directly within the Websites, in order to provide information about SME Guru’s solutions, to contact and be contacted by SME Guru’s Live support service.

3.7.12.2      Third-Party AI Model(s) Utilised. SME Guru AI Chatbot is integrated with the following third-party AI model: OpenAI ChatGPT.

3.7.12.3      Types of Data Shared with aforementioned AI model to enhance the functionality and performance of our Chat Supports are, (1) User Input Data which can includes any text/voice/image/video provided by users during the interaction, (2) Contextual Data which may include data related to the conversation context such as previous interactions, preferences, and settings, and (3) Non-Personal Data such as aggregate and anonymized data for analytical purposes.

3.7.12.4     Purpose of Sharing Data with AI Model. The data shared with aforementioned AI model is used to (1) Enhance User Experience to provide accurate, relevant and context-aware responses on SME Guru’s Solutions, (2) Improved Chat Supports Performance by continuously refine and improve the natural language understanding and response generation capabilities, and (3) Customisation by personalising user interaction based on their preferences and past behaviour.

3.7.12.5      How aforementioned AI model use the data and its potential impact on user.

3.7.12.5.1   The data are used to (1) Process and Generate Appropriate Responses, (2) Context Management to provide coherent and relevant interactions, (3) Enhance the AI Model understanding of language and improve further interactions.

3.7.12.5.2  The impact on users are (1) Improved Interactions; Users can expect more intuitive and helpful responses, (2) Personalisation; Interactions are more tailored to individual preferences and needs and (3) Privacy Considerations; User data is processed by third-party AI model, and will be advised not to provide any sensitive prior to the start of the Chatbot interaction. Such sensitive data are but not limited to: Individuals’ Political Opinions, Individuals’ Religious Beliefs, Individuals’ Sexual Orientation, Individuals’ Physical and Mental Health Data, Individuals’ Financial Data, and Business’ Trade Secret.

3.7.12.6     User Control and Opt-Out Options. Users have options to control or opt out of data sharing with our AI Chatbot Support by (1) not interacting with any SME Guru AI Chatbot Support, and (2) requesting the deletion of their Chat by contacting our team at hello@smeguru.ai and provide the name of the Chatbot, date and time of interaction.

3.7.12.7     Responsible and Ethical use of Data. (1) SME Guru maintains transparency with our users about how their data is used and provide clear options for control and opt-out. (2) SME Guru conducts regular audits of our data sharing practices to ensure compliance with our privacy policy.

4                 WHO WE SHARE YOUR INFORMATION WITH AND WHY

4.1              We may share your information as detailed below:

4.2              Third-party service providers that help us to deliver the services and allow us to operate our businesses.

4.2.1          Solutions Providers. As the provider of SME Guru’s Solutions, we share the data we collect from you with service providers as necessary in order to provide you with the Solutions. This is to ensure your calls, messages, emails, etc., reach the people you want to contact.

4.2.2          Business Operations Vendors. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. We only work with carefully selected vendors, and we require any vendors with whom we share personal data to protect the confidentiality of such information and use it solely for the purposes for which it was shared.

4.2.3          Partners. In the event that you purchase Solutions offered by SME Guru or a partner through a special marketing arrangement (for example, through a co-branded advertisement or offer, or an arrangement where we and a partner market or offer the other's products or services), we may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.

4.2.4          Google. Our Solutions complies with the Google API Services User Data Policy, including the Limited Use requirements. We understand the importance of protecting user data and have implemented measures to ensure compliance with the policy. We only use user data for the purposes outlined in our privacy policy and do not share or sell user data to third parties. By using our Solutions, you acknowledge and agree to our compliance with the Google API Services User Data Policy.

4.2.4.1        Google Drive: We only read the list of Spreadsheets to allow you to select the Spreadsheet you want to work with.

4.2.4.2        Google Sheets: We allow you to get data and update your Spreadsheet.

4.2.4.3        Google Calendar: We read the list of events on your calendar to avoid overbooking. Also, we add events to your Calendar when a customer book an appointment.

4.2.4.4        Dialogflow: We use Dialogflow to allow you to automate customer services using Dialogflow. We only use Dialogflow to detect user intents.

4.2.5          The Solutions’ use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. See privacy and API services user data policy.

4.2.6           Meta/ Facebook/ Instagram/ WhatsApp. SME Guru may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows the Solutions to connect with the User's account on the Facebook social network, provided by Facebook Inc.

4.2.7          For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy. The permissions asked are but not limited to the following:

4.2.7.1      Basic Information. By default, this includes certain User’s Data such as ID, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

4.2.7.2        About Me. Provides access to the 'About Me' section of the profile.

4.2.7.3        Business Management API. Read and write with Business Management API.

4.2.7.4        Contact Email. Access the User's contact email address.

4.2.7.5        Instagram Basic. Allows reading an Instagram account profile information and media.

4.2.7.6       Instagram Manage Comments. Allows the creation, deletion and hiding of comments on behalf of the Instagram account linked to a Page. Also allows reading and responding to public media and comments that a business has been photo tagged in or @ mentioned in.

4.2.7.7        Manage Pages. Enables the application to retrieve access tokens for Pages and Applications that the User administrates.

4.2.7.8        Managing Page Advertisements. Allows managing advertisements associated with the Page.

4.2.7.9        Page Messaging. Send and receive messages through a Facebook Page.

4.2.7.10      Pages Manage Engagement. Allows creating, editing and deleting comments posted on the page.

4.2.7.11      Pages Manage Metadata. Allows subscribing and receiving webhooks about activity on the Page, and updating settings on the Page.

4.2.7.12      Pages Manage Posts. Allows the creation, editing and deletion of the User’s Page posts.

4.2.7.13     Pages Read Engagement. Provides access to content (posts, photos, videos, events) posted by the Page, access to followers’ data (including name, PSID), and profile picture, and access to metadata and other insights about the Page.

4.2.7.14      Pages User locale. Provides access to the User’s locale through the connected Page.

4.2.7.15      Pages User Timezone. Grants access to a user’s time zone through the connected Page.

4.2.7.16      Show List of Managed Pages. Provides the access to show the list of the Pages that the User manages.

4.2.8           For more information about WhatsApp privacy policy.

4.2.9          Third Party Websites. Our Solutions and Websites may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

4.2.10        Compliance with law enforcement requests and applicable laws; enforcement of our rights. We may disclose personal data as required by applicable law, regulation, legal process or government request; to protect SME Guru, our Solutions, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms.

4.2.11       With your explicit consent. We share information about you with third parties when you give us consent to do so. For example, we often display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity.

4.2.12        Sharing with senders and recipients of communications. The name on your account, or a portion thereof, and/or your phone number may be displayed to people that you make calls to and to other users of the Solutions so that they may contact you.

5                 HOW WE PROTECT AND PROCESS YOUR INFORMATION AND DATA

5.1            SME Guru takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data that we transmit and maintain. While we strive to protect your information, we cannot ensure a 100% guarantee of security, especially for Solutions that rely upon the internet. Therefore, you acknowledge the risk that third parties may gain unauthorised access to your information.

5.2            The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the SME Guru, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation SME Guru (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by SME Guru. The updated list of these parties may be requested from the SME Guru at any time.

5.3              Legal basis of processing. SME Guru may process Personal Data relating to Users if one of the following applies:

5.3.1          User Consent. Users have given their consent for one or more specific purposes. Note: Under some legislations SME Guru may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

5.3.2           Performance of Agreement. Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

5.3.3           Legal Obligation. Processing is necessary for compliance with a legal obligation to which SME Guru is subject;

5.3.4           Public Interest or Official Authority. Processing may be carried out for tasks in the public interest or exercising official authority vested in SME Guru;

5.3.5           Legitimate Interests. Data processing may be necessary for the legitimate interests pursued by SME Guru or by a third party.

5.4           Clarification of Legal Basis. SME Guru is committed to clarifying the specific legal basis for data processing, including whether providing personal data is a statutory or contractual requirement, or necessary to enter into a contract.

5.5             User Responsibilities. You are responsible for any activity under your account(s) using your account passwords or other credentials. We urge you to take precautions to protect your personal information when you are on the Internet. You undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable at hello@smeguru.ai if you think your password has been compromised.

5.6           SME Guru is not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username, password, or any other credentials.

6                 HOW LONG WE STORE YOUR INFORMATION FOR

6.1             We store your information until it is no longer necessary to provide the Solutions or otherwise relevant for the purposes for which it was collected. This time period may vary depending on the type of information and the Solutions used, as detailed below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Solutions. You cannot be identified from anonymised information retained or used for these purposes.

6.1.1           Customer Account Information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Solutions. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Solutions.

6.1.2          Customer Usage Information. While you are an active customer, we retain the communications usage information generated by your use of the Solutions until the information is no longer necessary to provide our Solutions, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Solutions.

6.1.3          Marketing information, cookies and web beacons. If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Solutions, such as when you last opened an email from us or visited our websites. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

7                 HOW TO ACCESS AND CONTROL YOUR INFORMATION

7.1             How and When. We will confirm receipt of your verifiable request within 10 business days and provide information about how we will process your request. We will respond to your request within 30 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 60 days to fulfill your request. Our disclosure(s) will cover the preceding 12-month period. Should we deny your request, we will explain to you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, and or may limit the number of requests per year, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

7.2.            Your Choices. To request deletion of your account(s), please inform us in writing by sending an email to hello@smeguru.ai with your request. Or you may log into your account to delete, there is 24 hours cooling period upon deletion. Afterwhich the account will be deleted. You should know that deletion of your account(s) will result in you permanently losing access to your account(s) and all customer data to which you previously had access through your account. Please note that certain data associated with that account may nonetheless remain on the servers in an aggregated or anonymised form that does not specifically identify you. Similarly, data associated with your account that we are required by law to maintain will also not be deleted.

7.3.            Access to your account information. You can access or amend your account information, such as full name, contact information, and billing information when you log into your account. You are responsible for ensuring that the information on file with us is current and accurate. You may access and update your information by logging into your account or contacting us as described in this privacy policy.

7.4              Opt Out of Communications. You may opt-out of receiving promotional communications (if any) from us by using some or all of the following methods:

7.5              Clicking or checking the appropriate option at the point of collection;

7.5.1           the unsubscribe link within each email;

7.5.2           or by contacting us at hello@smeguru.ai as provided below to have your contact information removed from our promotional email list or registration database.

7.5.3           Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Solutions.

7.5.4         Withdraw their consent at any time. Users have the right to withdraw their consent at any time regarding the processing of their personal data. This includes instances where consent was previously given for processing related to direct marketing purposes or sharing with third parties for their marketing use. Withdrawal of consent can be requested by contacting us. Regardless of prior consent, users retain the right to opt-out of such processing without detriment.

7.5.5          Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

7.5.6           Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.

7.5.7           Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

7.5.8        Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

7.5.9          Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

7.5.10        Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

7.5.11         Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Details about the right to object to processing

7.6           Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

7.7          Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

7.8.            How to exercise these rights. To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must: (1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative. (2) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal data in our possession relates to you. If you cannot personally submit a verifiable request, you can authorize a person to act on your behalf.

8                 CHILDREN’S PRIVACY

8.1              We do not knowingly collect information from children under 13. We will take steps to delete it if we learn we have collected it.

8.2             We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Solutions are directed to children under the age of 13.

8.3              If you learn that your child has provided us with personal information without your consent, you may alert us at hello@smeguru.ai.

8.4             If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

9                 INTERNATIONAL USERS

9.1              By using the Solutions, you will transfer data to Singapore.

9.2              If you are visiting from the United States, European Union or other regions with laws governing data collection and use, you agree to the transfer of your information to Singapore and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

10               OTHER IMPORTANT INFORMATION

10.1          Changes to this policy. In line with our commitment to transparency and compliance, SME Guru regularly reviews and updates this Privacy Policy to reflect changes in regulations, technology, and our business practices. We strive to ensure that this policy remains accurate, comprehensive, and aligned with the latest developments in data protection. As part of this effort, we aim to review and update the policy at least quarterly, though updates may occur more frequently if significant changes are warranted. We encourage all users to check back regularly for updates to stay informed about how their data is handled and to ensure continued understanding of our privacy practices.

10.2           SME Guru may, at its sole and absolute discretion, revise this Privacy Policy from time to time. In the event we make changes to this Privacy Policy, we will let you know by posting a notice on our Websites and state the “EFFECTIVE DATE” displayed at the top of this Privacy Policy, in relation to substantive changes that broaden the types of personal data collected or their usage, we will notify you via email to the email address associated with your account, via our Websites, or by some other means;

10.3         It is your responsibility to review the terms of this Privacy Policy from time to time, particularly if the most recent revision date is after the date on which you last reviewed them;

10.4         Any changes will become effective as specified in the notice. If you access the Website and/or use the solutions, products and/or services after notification of a change in this Privacy Policy, you will be bound by all such changes.

10.5            We believe that educating our users is essential for fostering a safe and secure online environment. Below are some recommended educational resources:

10.5.1       Data protection commission - Singapore: explore the official website of the data protection commission of Singapore to learn more about data protection laws and regulations in Singapore. Visit https://www.pdpc.gov.sg for more information.

10.5.2       Personal data protection act 2012 - Singapore: access the personal data protection act 2012 of Singapore to understand the legal framework governing personal data protection in the country. Read the full PDPA act.

10.5.3       Online safety tips from cyber security agency of Singapore: discover practical tips and resources for staying safe online provided by the cyber security agency of Singapore. Learn more at here.

10.6         Customer Responsibilities on AI Model(s) Integration.

10.6.1      AI Model(s) Integration. Integration with the any AI model is not automatically included in our chatbot builder platform. Customers are responsible for:

10.6.1.1  Obtaining API Keys: Customers must acquire their own API keys from the AI model providers. This integration is required to be set up and managed by the customer.

10.6.1.2  Configuring Integration: Customers must integrate these AI models into our platform using their OWN acquired API keys. Guides on the configuration can be found in the help documentation within the login Dashboard.

10.6.1.3   Privacy Policy: Customers must implement and maintain their own privacy policy that complies with relevant data protection laws and regulations. This policy must cover the use of our SME Guru solutions and any associated AI integrations, ensuring transparency with their own users about how data is collected, used, and protected.

10.6.1.4   Data Protection Compliance: Customers are required to incorporate all applicable data protection laws and regulations, such as PDPA, GDPR, CCPA, and others, when utilising AI model(s) for their businesses and/or their customers. This includes securing user consent where necessary and implementing adequate security measures to protect personal data.

11               HOW TO CONTACT US

11.1         For any data protection and privacy compliance concern please write and attention to Data Protection Officer (DPO). We value your feedback on our privacy practices and policies. Your input helps us continually improve our services and ensure that we meet your privacy expectations. Whether you have questions, concerns, or suggestions regarding our privacy policy, we encourage you to reach out to us. You can submit feedback or inquiries by emailing us at hello@smeguru.ai. We are committed to addressing your feedback promptly and transparently. Thank you for helping us maintain the highest standards of privacy protection.

11.2            Attention to: Data Protection Officer (DPO), SME Guru Pte. Ltd.

11.2.1         Postal Address: 60 Paya Lebar Rd, #07-54 Paya Lebar Square, Singapore 409051

11.2.2         Email: hello@smeguru.ai

12               COOKIES AND TRACKING NOTICE

12.1            A cookie is a small text file that a website saves on your computer or mobile device in order to facilitate and enhance your interaction with that Solutions. We or our service providers may use cookies and equivalent technologies such as clear gifs, web beacons, pixel tags, JavaScript, device fingerprinting, and third-party cookies on our websites and, where relevant, in our promotional emails. See may see our Cookie Policy in details.

12.2            They also help us track users, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and Solutions.

12.3            Learn more about when and how we use cookies and tracking technologies and some of our service providers:

12.3.1        When it's strictly necessary. These cookies and other technologies enable us to recognize you when you return to our Solutions and to maintain your web session so you can more easily navigate the subscription process or your viewing of your call details. They are also essential for you to access secure areas of our sites, for example, to make payments.

12.3.2        For Performance and Analytics. These cookies and similar technologies collect statistical information about how you use our Websites so that we can improve your user experience. We use cookies to identify the number of unique visitors we receive to different parts of the Websites and identify where leads originate. This helps us for our legitimate interests of improving the way our Websites works, for example, by ensuring that users are finding what they are looking for easily.

12.3.3        To enable functionality. These cookies and similar technologies can tell us what your communications preferences are. They can help you fill out forms on our sites more easily. They also enable customization of the layout and/or content of the pages on our sites.

12.3.4.       For Targeted Advertising. These cookies and other technologies record your visits to our Websites, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Websites more relevant to your interests. We may also share this information with third parties for this purpose.

12.3.5.       Social media cookies and widgets. We use social media platforms to advertise to you online and to monitor the success of our advertising (for instance by receiving reports when you click on our ads on Facebook, and others). We summarise the main advertising and social media partners who drop cookies below:

12.3.5.1      Facebook Custom Audience: This service from Facebook enables us to display personalized ads to people on our email lists when they visit Facebook. We provide personal information such as your email address and phone number in encrypted form to Facebook (so they cannot be seen by anyone at Facebook) to enable Facebook to determine if you are a registered account holder with Facebook.

12.3.6        How to control cookies. You can control and/or delete cookies as you wish - for details, see this link. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. You will not be able to opt-out of any cookies or other technologies that are "strictly necessary" for the Solutions. Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the site.