PRIVACY POLICY FOR SmileApp's iOS APPLICATION

Last Updated: May 9, 2013

SmileApp by Smile Interactive Co., Ltd. . (SmileApp), respects the privacy of users of our iOS Application ("Application"), and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. These privacy policies (the "Privacy Policy") are intended to describe for you, as an individual who is a user of the Application the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

We encourage you to read this Privacy Policy carefully when using the Application or transacting business with us. By using our Application, you are accepting the practices described in this Privacy Policy. SmileApp is a part of the Smile Interactive Co., Ltd. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

INFORMATION WE COLLECT ABOUT YOU

In General. We may collect personal information that can identify you, such as your name and email address, and other information that does not identify you. When you provide personal information whether through the Application or by third party network, the information may be sent to servers located in Thailand and other countries around the world.

Information you provide. We may collect and store any personal information you provide to us, including personal information that may be contained in any comment or other submission you make from the Application. This includes identifying information, such as your name, address, photos, e-mail address, and telephone number and, if you purchase a subscription or transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender and age, and other demographic information.

Information from other sources. We may also periodically obtain both personal and non-personal information about you from other SmileApp businesses, business partners, social networks, contractors and other third parties and add it to our account information or other information we have collected. Examples of information that we may receive include: updated delivery and address information, purchase history, and additional demographic information.

Information about others. We may also collect and store personal information about other people that you provide to us. If you use the Application to send others (friends, relatives, colleagues, etc.) messages, we may store your personal information, and the personal information of each such recipient.

Use of internet technologies to collect information. We use various technologies to collect information from your device and about your activities on the Application.

General Information collected automatically. We automatically collect information from your iOS device when you use our Application. This information includes user activity while on the Application, access times, and length of access. This information is only used for seamless interaction for the user and the Application.

Tracking. We may obtain information as a result of data being sent to our servers from our software "agent" that may be embedded in an end user's mobile application. We aggregate that data, which tracks information such as use sessions, length of sessions, pages viewed and information about your device. This data is aggregated for analysis and understanding of our user's interaction with the application.

Other Technologies. We may use standard Internet technology, to track your use of the Application. The information we obtain in this manner enables us to customize the services we offer our users to deliver targeted advertisements and to measure the overall effectiveness of our advertising, content, or other activities.

Information collected by third-parties. We may allow third-parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements or place ad tags on our Application. These companies may use tracking technologies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, we do not provide any personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

HOW WE USE THE INFORMATION WE COLLECT

In General. We may use information that we collect about you to:

• deliver the products and services that you have requested;
  
• manage your account and provide you with customer support
  
• perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
  
• communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our group of companies or other third parties;
  
• verify your eligibility and deliver prizes in connection with contests and sweepstakes;
  
• enforce our terms and conditions;
  
• manage our business and
  
• perform functions as otherwise described to you at the time of collection.
  

Financial information. We may use financial information or payment method to process payment for any purchases, subscriptions or sales made in the Application, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

WITH WHOM WE SHARE YOUR INFORMATION

We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on the Application.
Personal information. We do not share your personal information with others except as indicated below. We may share personal information with:

Authorized service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include processing credit card payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Application functionality, and supporting contests, sweepstakes, surveys and other features offered through our website. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

Business partners: When you make purchases or engage in promotions offered through the Application, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant′s offer or program, you authorize us to provide your email address and other information to that merchant.

Other group of businesses. We are part of Smile Interactive Co., Ltd. We may share information we collect, including personal information, with our group of companies. Sharing information with our group of companies enables us to provide you with information about a variety of products and services that might interest you.

Other Situations. We also may disclose your information:

• In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
  
  
• When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies.
  
  
• In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  

Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

Aggregated and non-personal information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with third parties and our group of companies to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our partners the number of visitors to our Application and the most popular features or services accessed. This information does not contain any personal information and may be used to develop content and services that we hope you and other users will find of interest.

THIRD-PARTY WEBSITES

There may be places in the Application where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

HOW YOU CAN ACCESS YOUR INFORMATION

You can review your personal information by contacting customer support at: support[at]smileapp.com

YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION

• You can choose not to provide us with certain information, but that may result in you being unable to use certain features of the Application because such information may be required in order for you to access certain content; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions within our Application.
  
  
• You may tell us not to share your personal information with third parties for direct marketing purposes by send the email.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information.

However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. Users should also take care with how they handle and disclose their personal information. Please refer to the Federal Trade Commission′s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

CHILDREN′S PRIVACY

Our Application is intended for a general audience, over the age of 13. We do not knowingly collect personal information from children under the age of 13.

USING OUR MOBILE APPLICATIONS AND VISITING OUR WEBSITES FROM OUTSIDE THAILAND

This Privacy Policy is intended to cover collection of information on the Application from residents of Thailand. If you are using the Application outside Thailand, please be aware that your information may be transferred to, stored, and processed in Thailand where our servers are located and our central database is operated. The data protection and other laws of Thailand and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

NO RIGHTS OF THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "Last Updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by prominently posting notice of the changes on the Application. We recommend that you check the Privacy Policy from time to time to inform yourself of any changes.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or our information-handling practices, please contact us by email to support[at]smileapp.com

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