Privacy Policy

Global Web Privacy and Cookie Policy

Please Read Carefully: Smili, along with its subsidiaries and affiliates (collectively, “ADV,” “we,” “us,” or “our”), understand the significance of safeguarding your privacy. This Global Web Privacy and Cookie Policy (“Policy”) pertains to your usage of our global public websites (collectively, the “Site”), as well as your interactions with ADV officers, employees, and contractors.

This Policy aims to provide you with insights into how we gather, utilize, protect, and reveal your personal information and informs you of your choices to make well-informed decisions while using the Site. Additionally, we offer information on how you can reach out to us regarding our privacy practices.

Through use of the Site you are giving your acceptance of this Policy. This Global Web Privacy Policy delineates how ADV accumulates, employs, and divulges particular personal information gathered via this Site. Kindly take note that, to the extent allowed by relevant laws, your utilization of this Site signifies your comprehension and consent to the terms outlined in this Global Web Privacy Policy. This Global Web Privacy Policy is integrated into and forms a part of the Terms of Use, which govern the general use of the Site.

The Types of Information We Collect.

Information Collected Directly from You: We collect information directly from you when you opt to partake in our offers and programs or when you directly provide us with information. Examples of information gathered directly from you include your name, email address, postal address, username, password, phone number, age, date of birth, your IBO enroller or sponsor's name, demographic information, future communication preferences, and contact information for friends you wish to refer. Information Collected During Site Visits or Use of Services: We employ cookies and other technologies to accumulate information about your visits to our sites, usage of our services, and viewing of online advertisements. This data may include your browser type, operating system, web pages viewed, links clicked, IP address, sites visited before arriving at our Site, opened and/or forwarded IM emails, accessed IM offers or links via emails, information regarding visits to the Personal Web Site of your IBO enroller, and your product or service choices and preferences.

How We Use Your Information.

Communications With You – Offerings and Services You've Expressed Interest In:

When you visit our Site or engage in transactions, you may be required to register or provide personal and account information. This information may be used to contact you about offerings or services you have shown interest in. IM has a legitimate business interest in using the personal information we collect to provide requested services. If you wish to discontinue further contact based on this information (by utilizing our opt-out process described below), we will honor your preferences.

Communications With You – Newsletters and Marketing Purposes:

To keep our users and clients informed about our latest news, products, and services, we may send emails and marketing communications to the email address provided during registration or while requesting information from us. We adhere to applicable laws when using your personal information for this purpose, and where required (e.g., in the EU), we rely on your consent. It's important to note that we may occasionally partner with third parties to send marketing communications that promote third-party products and services (e.g., those of our business partners) in addition to our own. If you initially opted-in to our email lists, newsletters, or promotional offerings and later decide you no longer wish to receive such communications, you may unsubscribe by following the instructions provided in each email we send (or use the opt-out process described below).

Professional Interactions With You – Relationship Management:

We may use your relationship data (collected when you communicate with an ADV employee or agent via phone or email) to provide requested products and services and manage our relationship with you. Additionally, we may use certain de-identified and aggregated data about our IBOs, members, or visitors to our Site for internal data analytics purposes. IM has a legitimate business interest in utilizing the personal information we collect to provide requested products and services and enhance our support for IBOs and members. With your consent, we may send you information or services of a promotional nature that we believe may be relevant to you.

Other Uses: The personal information we obtain about you may also be used for the following purposes: Operating, evaluating, and enhancing our business, including developing new products and services. Managing our communications, assessing the effectiveness of our advertising, analyzing our products, services, websites, mobile applications, and other digital assets

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Facilitating the functionality of our websites, mobile applications, and other digital assets

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Preparing and providing aggregated data reports, which may include anonymized information

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Enforcing our Terms and Conditions or other legal rights.

We may also utilize the information in other ways for which we provide specific notice at the time of collection. If you object to the use of information in other ways, you can contact us at smili.tech

Information Provided to Us About You by Third Parties. Third-Party Content:

Our Site may feature or embed content provided by third-party vendors. This content may contain links to websites not operated by ADV or may request personal information. For instance, such content may request an email address for subscription to alerts. This information is collected by our vendors, not by us. In some instances, these vendors may share the personal information they collect from you with us. We are not responsible for the privacy practices of our vendors, and we encourage you to review their privacy policies to comprehend how they will utilize and share the personal information you provide to them.

Third-Party Usage: You may also choose to share your information separately with other websites or entities, such as those that compile professional marketing lists, to receive special offers and promotions from their affiliates. These websites or entities may share your information with us. ADV is not responsible for, and assumes no liability if, a partner, other website, or entity collects, uses, or shares any information about you in contravention of its own privacy policy or applicable law.

Third Parties with Whom We Share Your Personal Information. Third Parties for Retargeting Advertising:

In certain cases, we may share information about your use of our Site with third-party vendors to present you with more relevant advertising. For example, our vendors may track your browsing activity on our Site using cookies to display ads tailored to your interests when you browse the Web or use social media. In some instances, our vendors may also share information about your browsing activity on our Site with us for analytics purposes. ADV relies on your consent for such processing of your personal information. More information on these cookies, including how to give or withdraw your consent, is available in our Cookie Policy below.

Service Providers:

We may share your personal information with companies acting as authorized agents or contractors to provide our services. These may include, but are not limited to, the following categories of service providers:

Infrastructure and IT service providers, including cloud service providers, Help Desk Support, Academy Video Support, Zendesk.
Business service providers.
Marketing, advertising, and communications agencies.
External auditors and advisors.
Cookie analytics providers.
Online advertisers.
Providers of website testing and analytics services.
Translation Service.

Each service provider must agree to implement and uphold reasonable security procedures and practices appropriate to the nature of your information to safeguard your personal information from unauthorized access, destruction, use, modification, or disclosure. Since we operate globally, we may transfer your information to countries or jurisdictions that may not provide the same level of data protection as the country where you are based. If such a transfer occurs, we, or our vendors as applicable, will provide the necessary safeguards mandated by applicable law to ensure the protection of your information. More information on International Data Transfers is available below.

When we share your personal information for our legitimate interests, you have the option to object to this disclosure. Please note that objecting to the disclosure of your personal information for ADV's legitimate interests may impact the products and services we provide to you. Additional information on Your Rights is outlined below.

Legally Affiliated Entities:

In the event of a merger or the transfer of our assets, Site, or operations, ADV may disclose or transfer your personal information in connection with such transactions. If such a transfer occurs, we will notify you through email or by posting a prominent notice on our Site for 30 days, informing you of any change in ownership of ADV that results in a change of control over your personal information. Additionally, we may share your personal information with ADV Independent Business Owners (“IBOs”) affiliates to provide or offer products or services to you.

Legally Compelled Disclosure:

We will disclose your personal information when required by law, such as in response to a court order, subpoena, or other legal obligation, lawful requests by public authorities (including national security or law enforcement agencies), or in special cases when we have reason to believe that disclosing your personal information is necessary to identify, contact, or initiate legal action against someone who may be causing harm or interference (whether intentional or unintentional) to our rights or property.

International Data Transfers. Processing in the US and Elsewhere upon Registration on This Site:

ADV operates as a global entity. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed in countries other than the one where the information was originally gathered, including the United States and other locations that may have less stringent data protection laws than your home country. When we transfer your information to countries other than the one in which the information was originally collected, we will safeguard your information in accordance with this Policy or as otherwise communicated to you at the time of data collection (e.g., via specific privacy notices for certain programs) and will adhere to all applicable data protection laws during such transfers. If you are situated in a jurisdiction outside the United States, the cross-border transfer of personal information is essential to provide you with the requested information and/or perform any requested service. To the extent allowed by law, such submission also implies your consent to the cross-border transfer.

Regarding transfers originating from the European Economic Area (EEA) to the United States and other non-EEA jurisdictions, ADV has executed EU Standard Contractual Clauses concerning personal information collected within the EEA and transferred to ADV in the United States and other locations. Where applicable by law, you may request further information on the safeguards we have established to secure the transfer of your data outside the EEA by reaching out to us as indicated below.

Disclosure and Liability for Onward Transfer.

ADV is obligated to disclose personal information in response to lawful requests from public authorities, including fulfilling national security or law enforcement requirements. ADV may, as disclosed above in "Third Parties with Whom We Share Your Personal Information," onward transfer personal information to third parties. Complaints. ADV is committed to addressing complaints regarding the collection or use of your personal information. Individuals with inquiries or complaints can contact at smili.tech. Security. ADV endeavours to uphold the security of your personal information and your preferences for its intended use. We utilize Secure Socket Layers (SSL) technology to protect sensitive personal information like credit card numbers during transmission. Your personal information is stored on secure servers, and we employ procedures designed to safeguard the personal information we collect from unauthorized access, destruction, use, modification, or disclosure.

While we take (and require our third-party providers to take) commercially reasonable security measures concerning your personal information collected and stored on the Site, we cannot guarantee that any of your personal information stored on our servers or transmitted to or from a user will be entirely free from unauthorized access. Consequently, we disclaim any liability for theft or loss of, unauthorized access to, damage to, or interception of any data or communications.By using the Site, you acknowledge that you understand and agree to accept these risks.

How Long We Keep Your Personal Information.

We will retain the personal information we collect about you only for as long as necessary for the purposes for which it was collected and to the extent permitted by applicable laws. We take measures to ensure that, when we no longer need to use your personal information, we either remove it from our systems and records or anonymize it so that you can no longer be identified from it (unless retaining your information is required to comply with legal or regulatory obligations to which we are subject).

Your Privacy Rights. Marketing Communications:

Upon registering on this Site, we may ask you to specify whether you would like to receive emails and electronic communications from us, such as offers, news, reports, and other promotional communications. You may withdraw your consent or opt-out of receiving such communications at any time by reaching out to us as described below. Furthermore, when we process your personal information for our legitimate interests, you have the right to object to such processing. Please be aware that objecting to this type of processing may impact our ability to carry out tasks outlined in this policy. You may contact us:

(a) By following the Opt-Out or unsubscribe instructions included in the body of any marketing email from us. (b) By contacting us at smili.tech, including a copy of the email you received and typing “Remove” in the subject line. (c) By mail: Office No : B-116, Abu Hail Building 13, Abu Hail, Dubai, UAE, Attention: Chief Financial Officer.

Electing not to receive newsletters or promotional and marketing correspondence from us will not: Prevent us from communicating with you, by email or other means, concerning your existing or past relationship with us. (ii) Prevent us, including our employees, contractors, agents, and other representatives, from accessing and viewing your personal information for the purpose of maintaining and enhancing the Site.

Requesting Access to Your Personal Information and Other Rights:

You may also have rights under applicable law to request access to, review, correct, delete, port, or object to the processing of your personal information by us, and you may file a complaint with a supervisory authority if necessary. To exercise these rights, please submit your request to smili.tech.

Changes to this Policy

ADV is a rapidly evolving global business. We will periodically assess this Policy in light of new technologies, services, business practices, and the needs of our clients, and we will make adjustments as needed. If we make any substantial changes to this Policy, we will update it here and, in the case of significant changes, provide more prominent notice (including email notifications for certain services) of the Policy revisions.

Data Protection Officer.

We have appointed a data protection officer (“DPO”), where required by local law. If you have questions or concerns about our personal data policies or practices, you may contact at smili.tech.

UAE Residents Privacy Notice.

If you are a UAE resident, details regarding the personal information we collect about you and the business or commercial purposes for which it is used can be found in The Types of Information We Collect and How We Use Your Information section of this Policy.

For more information on our privacy practices and how to exercise your rights under UAE law, please see UAE Consumer Privacy Policy. However, please note that we do not currently sell data triggering the opt-out requirements outlined in that statute.

Cookie Policy – Automatic Data Collection

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By browsing our Site, you consent to our use of cookies.

What is a Cookie: A cookie is a small text file that a website stores on your personal computer, phone, or other devices, containing information about your navigation on that website. Cookies enhance browsing and make it more user-friendly. A cookie typically includes the name of the server it originated from, the cookie's expiration date, and a value, often a randomly generated unique number. Cookies do not grant access to or harm your computer. How we use Cookies: We utilize browser session cookies (temporary cookies that are deleted from your device's memory when you close your internet browser or power off your computer) and persistent cookies (stored on your device until they expire, unless you delete them prior). For more information about our privacy practices and to learn how to opt out of having your information used by third parties, please contact us at smili.tech.

Contact Us.

You are always welcome to reach out to us if you have any questions or concerns regarding this Policy, encounter issues related to your use of the Site, or wish to exclude your personal information from our direct marketing efforts. Our standard procedure is to maintain any communications from our Site visitors to enhance our service to each of you. You can contact us on smili.tech.