Privacy Policy

SMOLSITES PTE LTD

Last Updated: 10/11/2025

1. Introduction
Welcome to SMOLSITES PTE LTD (“we,” “us,” “our”). This Privacy Policy explains how we collect, use, and disclose information across all our services, including website development, digital marketing, business automation, and AI Voice Agent services (“Services”). It covers data from our business clients (“Clients”), their customers (“End-Users”), and visitors to our own website. We comply with the Singapore PDPA and the Australian Privacy Act.

We know this info is dense, so if you prefer something easier to read, see the lite version here.

2. Our Role: Data Processor and Data Controller

As a Data Processor: When we handle End-User data (e.g., website visitor info, AI call recordings, e-commerce orders) on behalf of our Clients, our Client is the Data Controller. They are responsible for the lawful basis of collection, and we process the data according to their instructions to provide the Services.
As a Data Controller: We are the Data Controller for our own business contact information (Client Data) and for data from visitors to our own website. We are also the Data Controller for any Anonymized and Aggregated Data we create to improve our services.

3. Information We Process
The specific types of personal data we process depend on the Services our Client has engaged us for. This may include, but is not limited to: Contact Information, Transaction Information, Appointment Information, Technical Data (IP addresses, cookies), and AI Voice Agent Data (call recordings, transcripts). For certain Clients (e.g., healthcare), we may process sensitive information as directed by the Client, who is solely responsible for obtaining explicit End-User consent. Our standard Services are not designed for the processing of sensitive data (such as financial account numbers or government-issued identifiers) or special categories of data (such as health information) unless explicitly covered by a separate Data Processing Addendum. The Client agrees not to provide such information to us through the standard Services.

4. How We Use Information

We use End-User data strictly to fulfill our contractual obligations to our Clients. This data is never sold to third parties or used for our own marketing.
We use Anonymized and Aggregated Data to analyze and improve our Services.
AI-Specific Processing: For AI Voice Agent Services, we process voice data, transcriptions, and conversation metadata to enable and improve conversational performance. Such data may be anonymized for model enhancement.

5. Cookies & Tracking Technologies
We use cookies and similar technologies (e.g., tracking pixels) for analytics, service improvement, and to support Client marketing campaigns. Visitors can manage cookie preferences via their browser settings.

6. Data Sharing and Disclosure (Sub-processors)
We may use additional sub-processors to support our Services. We may update this list periodically as our technology stack evolves. A complete and current list of our major Sub-processors is publicly available here: Sub-Processors.

7. International Data Transfers
To provide our Services, your information may be transferred to, and processed in, countries other than the one you reside in. These countries may have data protection laws that are different from the laws of your country. We specifically engage Sub-processors located in the United States and other jurisdictions as detailed on our Sub-processor List. When we transfer personal data internationally, we take steps to ensure that the information receives an adequate level of protection through lawful transfer mechanisms such as Standard Contractual Clauses (SCCs) or by ensuring the recipient is certified under an adequate data privacy framework.

7. Business Transfers
If SMOLSITES PTE LTD is involved in a merger or acquisition, information may be transferred. Client Data will remain subject to our Client’s instructions. Anonymized and Aggregated Data is a business asset that may be transferred to the new owner.

8. Data Security
We use appropriate technical and organizational measures to protect the information we process.

9. Data Breach Notification
In the event of a data breach likely to result in serious harm, we will notify affected Clients and relevant regulators as required under the Australian Notifiable Data Breaches (NDB) scheme and Singapore PDPA obligations.

10. Data Retention
We retain personal data for as long as necessary to provide the Services to our Clients, and as required by law.

11. Your Rights
Individuals have certain rights regarding their personal data under applicable privacy laws, including the right to access, correct, or request deletion of their data.

For End-Users: As we are typically the Data Processor for End-User data, any requests to exercise your data rights should be directed to our Client (the Data Controller) in the first instance. We will provide reasonable assistance to our Client to help them respond to these requests.
For Clients and Website Visitors: For personal data for which we are the Data Controller (e.g., our Client’s business contact information or data from visitors to our own website), requests can be made directly to us using the contact details provided below.

12. International Data Transfers
Your information, including personal data, may be processed and maintained on servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. Many of our sub-processors, such as those providing core AI and cloud infrastructure, are based in the United States. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and that adequate data protection safeguards (such as Standard Contractual Clauses or other lawful mechanisms) are in place before transferring personal data outside of Singapore or Australia. Your use of our Services represents your consent to this transfer.

13. Contact Us
If you have any questions about this Privacy Policy, please contact us at hello@smolsites.com