Privacy Policy
This Privacy Policy explains how personal information may be collected, used, disclosed, retained, and protected in connection with SmartGEPS. SmartGEPS seeks to process personal information in accordance with applicable Philippine data-protection law, including Republic Act No. 10173, the Data Privacy Act of 2012, and applicable implementing rules.
Operator / Personal Information Controller: HJCP Studio, operator of SmartGEPS
Privacy Contact: support@smartgeps.com
SmartGEPS is operated by HJCP Studio. For purposes of this Privacy Policy, HJCP Studio is the Personal Information Controller for personal information processed under its control in connection with SmartGEPS. The product-facing name “SmartGEPS” is used throughout this Policy.
1. Information We May Process
Depending on how SmartGEPS is used, information may include account and identity information such as name, username, email address, business or organization name; account verification information; license and activation information; transaction references and purchase records; support correspondence; and technical, device, security, diagnostic, authentication, and usage information reasonably necessary to operate, administer, secure, and troubleshoot SmartGEPS.
SmartGEPS does not need to receive every item of business data stored locally in the desktop application merely because that information is used by the software.
2. Locally Stored Business and Search Data
SmartGEPS is primarily desktop software. Search criteria, keywords, filters, saved opportunities, company-profile information, locally generated documents, preferences, saved sessions, and similar working information may be processed or stored locally on the user’s computer unless a particular feature requires or clearly indicates transmission to an online service.
Users are responsible for the security and backup of information stored on their own devices.
3. AI-Assisted and Automated Features
SmartGEPS may offer AI-assisted, machine-learning, automated analysis, recommendation, matching, summarization, classification, or similar functionality.
The information processed by a particular feature depends on how that feature is implemented. Where a feature requires information to be transmitted to an online or third-party processing service, SmartGEPS may process or transmit information reasonably necessary to provide that feature, subject to applicable law and appropriate notice.
This Policy does not promise that all present or future AI-assisted processing will occur only on the user’s device.
4. Opportunity Data
SmartGEPS processes publicly accessible procurement information originating from government and other public sources. SmartGEPS does not claim ownership of government procurement information merely because it processes, organizes, or displays it.
5. Payments and Transactions
Purchases may be processed using third-party payment services. SmartGEPS may receive and retain transaction-related information reasonably necessary to identify a purchase, confirm payment status, administer a license, reconcile transactions, prevent fraud, provide support, and satisfy legal or accounting obligations.
Where payment credentials or financial information are entered directly into a third-party payment service, SmartGEPS does not need to receive or store complete payment-card or equivalent credentials merely to complete that transaction.
Third-party payment services process information under their own applicable privacy and security terms.
6. How Information May Be Used
Personal information may be processed where reasonably necessary to:
- create and administer accounts;
- verify email or account information;
- provide, activate, validate, update, suspend, or administer licenses;
- process and reconcile purchases;
- provide customer support;
- send transactional, security, account, or service communications;
- maintain software and opportunity-data services;
- detect and prevent fraud, abuse, circumvention, and unauthorized access;
- investigate security incidents;
- troubleshoot technical problems;
- maintain business and transaction records;
- establish, exercise, or defend legal claims; and
- comply with legal obligations.
Where applicable law requires consent for a particular optional processing activity, SmartGEPS will seek consent in an appropriate manner rather than treating this Privacy Policy itself as blanket consent.
7. Legal Bases and Legitimate Processing
Depending on the activity and applicable law, processing may be necessary to perform or administer a contract or requested service, comply with legal obligations, protect legitimate interests such as security and fraud prevention, establish or defend legal claims, protect vital interests where applicable, or occur with consent where consent is the appropriate legal basis.
8. Sharing and Service Providers
SmartGEPS does not sell or rent personal information as a business practice.
Information may be disclosed to service providers or processors where reasonably necessary to operate SmartGEPS, including providers supporting infrastructure, communications, email delivery, payments, security, diagnostics, support, or other product functionality.
Information may also be disclosed where reasonably necessary to comply with law or lawful process, meet regulatory requirements, enforce agreements, investigate fraud or security incidents, protect rights or safety, or establish, exercise, or defend legal claims.
Service providers may process information in jurisdictions outside the Philippines. Where applicable, SmartGEPS will use reasonable measures required by law for such processing or transfer.
9. Transactional and Service Communications
SmartGEPS may send account verification messages, security notices, license or access notices, transaction confirmations, service notices, support responses, and other communications reasonably necessary to administer the user’s account or SmartGEPS services.
Marketing communications, if introduced, will be handled in accordance with applicable law and applicable preference or consent requirements.
10. Retention
SmartGEPS retains personal information only for as long as reasonably necessary for the purpose for which it was processed, legitimate business and security needs, account and license administration, transaction and accounting records, dispute resolution, legal claims, fraud prevention, or compliance with applicable law.
Different categories of information may have different retention periods. Information may be retained longer where reasonably necessary for legal proceedings, security investigations, fraud prevention, regulatory requirements, or the establishment, exercise, or defense of legal claims.
When information is no longer reasonably required and no lawful basis for retention remains, SmartGEPS will take reasonable steps to delete, anonymize, or otherwise dispose of it as appropriate.
11. Security
SmartGEPS uses reasonable administrative, organizational, and technical safeguards appropriate to the information and risks under its control. These may include access controls, authentication measures, security monitoring, technical protections, and other safeguards appropriate to the system concerned.
No computer, device, internet-connected service, transmission method, or storage system can guarantee absolute security. SmartGEPS therefore does not warrant that unauthorized access, loss, misuse, alteration, or disclosure can never occur.
Users are responsible for maintaining reasonable security over their own devices, credentials, locally stored data, backups, and networks.
12. Data Subject Rights
Subject to applicable law and lawful limitations, individuals may have rights concerning personal information processed by SmartGEPS, including rights to be informed, access personal information, request correction or rectification, object to certain processing, request erasure or blocking where legally available, obtain data portability where applicable, seek damages where provided by law, and lodge a complaint with the National Privacy Commission.
A request may be subject to reasonable identity verification before information is disclosed, changed, exported, or deleted.
Rights are not absolute. SmartGEPS may retain or continue processing information where permitted or required for legal obligations, contractual administration, fraud and security prevention, establishment or defense of legal claims, accounting requirements, or other lawful purposes.
13. Requests for Deletion or Correction
Requests may be sent to support@smartgeps.com.
Deletion of an account or personal information does not necessarily require deletion of every transaction, security, fraud-prevention, audit, or legal record where retention remains lawful and reasonably necessary.
Locally stored information on a user’s own computer may need to be removed by the user through SmartGEPS, Windows, or other applicable local controls.
14. Children
SmartGEPS is intended for business and professional use and is not directed to children. SmartGEPS does not knowingly seek to collect personal information from children for independent use of the product.
15. Changes to This Privacy Policy
SmartGEPS may update this Privacy Policy to reflect changes in law, processing activities, services, technology, or business operations. Material changes will be communicated or presented as required by applicable law.
16. Contact and Complaints
Privacy questions and requests may be sent to:
support@smartgeps.com
Individuals may also exercise any right to lodge a complaint with the Philippine National Privacy Commission where applicable.