Privacy Policy

Privacy Policy (GLOBAL)

Data Lake Technology PTE LTD (SG) & P.T. Data Lake Technology (known as SmartCart”) its shareholders, principals, and affiliated companies, as well as their respective officers and employees (collectively, “SmartCart Group”) provide services that allow you to earn rewards from uploading receipts, syncing your emails, taking part in activities in the application so you can obtain maximum benefits from your purchasing and in-app activities. To provide you with SmartCart’s services, we collect information about you. As described below, SmartCart is able to offer its services to you for free through the development and marketing of anonymous consumer data. We recognize that you should have the right to know how the data we collect and/or are provided with are used, processed, analyzed and disclosed, and what controls you have over that data once shared with us.

This Privacy Policy applies to all information SmartCart Group and any corporate affiliates collect and/or are provided with for current and former consumers in connection with all the products, services, websites, microsites and mobile applications we offer on behalf of ourselves or others, and constitutes our internal policy in protecting Personal Information as required by applicable laws and regulations, including but not limited to:

The European General Data Protection Regulation 2016/679 (the “GDPR”);
Hong Kong’s Personal Data Privacy Ordinance (Chapter 486 of the Laws of Hong Kong);
Indonesia’s Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions (the “EIT Law”);
Indonesia’s Government Regulation No. 82 of 2012 on the Implementation of Electronic Systems and Transactions (“GR No. 82”);
Indonesia’s Minister of Communication and Informatics (“MOCI”) Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems (“MOCI Regulation No. 20”).
The Singapore Personal Data Privacy Act of 2012; and
Philippine Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, as well as its implementing rules and regulations.

Please read this Privacy Policy carefully and contact us if you have any questions or concerns. You may rest assured that SmartCart Group take privacy and security seriously and are receptive to any feedback on these issues. If you have any queries, comments or concerns, or otherwise require any help, please feel free to contact us at

By ticking the consent box available on our mobile application and/or using our products or services, we assume that you have carefully read and agreed to our Privacy Policy, and verified, confirmed and consented to the accuracy, confidentiality and purpose of use of Personal Information about you and how the Personal and/or Non-Personal Information we collect and/or are provided with are used, processed, analyzed and disclosed.

In this privacy policy we describe the information we collect and how we use and share it. By using SmartCart’s websites, mobile apps, or services that facilitate the provision of such websites and mobiles apps (“Services”), and accepting the Terms of Service, you agree to this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES.

Unless defined otherwise in this Privacy Policy, all terms defined in this Privacy Policy have the same meanings given to them in our terms of services (“Terms of Services”). This Privacy Policy is an integrated, inseparable part of the Terms of Services.


Our rules of thumb:

Rule No. 1: We have never, we do not and we will never sell our users’ personal data

SmartCart will never transfer personal data to third parties. Our business model based on the production of statistics and quantifiable data relating to offline and online market purchases.
To produce these statistics, we anonymize and aggregate data we collect from you. These statistics do not represent user profiling in any way, and they do not allow for any proxies regarding a specific user of our services.

Rule No. 2: We are transparent and direct with our users

Before the user connects to SmartCart, we provide him/her with black on white details regarding our engagement to never sell any personal data to third parties and to only commercialize statistics based on anonymous data. All of this is then detailed in an intelligible and simple manner in our privacy policy.

Rule No. 3: We have made the choice to never use your data for advertising purposes

Contrary to a big part of the players on the web, SmartCart does not sell its users’ personal data. SmartCart’s activity has no advertising purposes. As such, if you use SmartCart, you will never be subject to solicited or unsolicited advertisements.


Scope of Privacy Policy

This Privacy Policy applies to all data and information collected by SmartCart. SmartCart considers personal information to be information that can be used to determine the actual identity of a specific individual and to contact that person, such as name, address, email address, and/or phone number. We do not consider personal information to include information that, taken alone, does not allow a third party to easily identify and contact a specific individual.


Highlights of what you are consenting to:

By using the Services, you are consenting to:
The collection, use, store and processing of all the information you provided in our application such as uploading receipts, personal demographic survey questions;

The collection, use, store and processing of information collected from the online accounts you connect to the Service, such as email receipts;


The use of cookies and related technology;

The sharing of anonymous transaction information with trusted third parties who work with us under strict confidentiality agreements.
The sharing of aggregated and anonymized data in relation to your purchases, with service providers and vendors;
The collection, use, sharing and other processing of your information as otherwise described in this Privacy Policy.
What information does SmartCart collect and/or provided with?
We may collect and/or are provided with the following types of information:


Information you provide

The personal and/or non-personal information that we receive is only limited to what is provided by users; such as, but not limited to; during the app’s sign-up process, users’ survey answers, receipt uploaded by users, etc. We will not collect any personal data without users’ consent. Every personal information we have are the information our users willingly and knowingly share.


Information Collected by Automated Means

We may obtain certain personal and non-personal information by automated means when you avail our Services. The type of information we collect by automated means may vary, but generally includes technical information about your computer, such as IP address or other device identifier. The information we collect also may include usage information and statistics about your interaction with our websites. That information may include the URLs of our web pages that users visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, and other information about how you used our websites.

In cases where you use a mobile device to access our sites we will receive information about the location of your device. In some cases, even if you are not using a mobile device, information about your general location may be discernible from your device’s IP address or the URLs we receive. If you access or use our sites or services with your mobile telephone, we may collect your telephone number.

Please note that if ads or other features on our site are provided by third parties, those parties also may use automated means of data collection that are subject to those third parties’ privacy notices and policies.

We use information we collect by automated means to understand our users and to determine their preferences. As a result, we can develop and deliver new or modified offerings, improved with our users’ preferences in mind. As described below, we also may use it to provide a more personalized user experience and to manage advertising.


Information from cookies

When you visit a SmartCart’s website and/or mobile application or click on a banner advertisement, we may send one or more cookies to your computer or any other device.

You can set your browser to refuse all cookies, delete previously stored cookies or to indicate when a cookie is being sent. However, some features or services of SmartCart website and/or mobile application may not function properly without cookies.


Email and Other Accounts

You may also provide information such as the login credentials for your email, social networking, or other Internet accounts that you consciously link to the Services. By linking the Services to your email or other Internet accounts, you authorize us to gather, parse, and retain information relating solely to your online and offline shopping and purchases. We do not collect any personal information from users’ email. Our scope is limited to emails that are filtered through e-commerce sender’s email address. We have not, do not and will never collect users’ personal information from users’ emails as we respect the privacy of our users.

If you grant SmartCart permission to access your email account, we will use the access only to collect purchase &/or engagement data. We will automatically collect information from your emails about purchase transactions including receipts, details of what was purchased, the merchant from which the goods/services were purchased, the amount spent and the date of purchase. Nevertheless, you do not have to grant us this access in order to use our Service.

We use the information collected from your email to provide you with our products and services, to improve these services, to conduct market research, and to produce and maintain aggregate statistics and provide market data services.

You should grant us this access only if you are comfortable with us having access to your emails. You may opt in anytime you wish to link your email account and may opt out anytime you wish for your email account to no longer be linked.


Log and other information

When a SmartCart website, mobile application, email, advertisement or other content served by or on behalf of us on other websites, microsites or mobile applications is accessed, we automatically record Personal and/or Non-personal Information about you that your browser and/or mobile application sends.

These logs typically include your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser, mobile application or Account(s) to us.

Other actions, such as interactions with advertisements, may also be included in our logs. During your visits to our website, microsites or mobile application, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.



The SmartCart mobile application may request permission to send you emails containing links to surveys in which you will be involved, and may also be presented with surveys within the application itself. Once you are in these surveys, your answers will be collected to the surveys and reused, by way of, among other ways, being processed, analyzed, stored, displayed, announced, sent and/or disclosed, and/or opening access to them.


Facebook Login

The SmartCart mobile application may request your mobile application permission to link with your Facebook account, if you use Facebook Login to access the application. If you grant the mobile application permission to access your Facebook account, Personal and/or Non-Personal Information from your Facebook profile including but not limited to your likes and interests will be collected. We may also provide you the ability to log into our website using sign-in services such as Facebook Login. These services will authenticate your identity and provide you the option to share certain Personal and/or Non-Personal Information with us such as your name and email address to pre-populate our sign-up form. Services like Facebook Login give you the option to post Personal and/or Non-Personal Information about your activities on our website(s) to your Facebook profile page to share with others within your network.


Mobile Device Information

SmartCart uses tools, including third party analytical software, to automatically collect certain anonymous data about your device that does not directly identify you, such as: (i) device properties, including, but not limited to unique or other device identifier; (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as country or region; (v) other similar data as reasonably required by SmartCart to enhance the Services and other SmartCart products and services.


How does SmartCart use my information?

To manage your Account(s)

We use, process and/or analyze Personal and/or Non-Personal Information about you that we collect and/or are provided with to manage your Account(s).

For example, we use Non-Personal Information you provide us and the purchase information we collect to track, process, post and fulfill Rewards you earn and to provide customer service.

In addition, we may use Non-Personal Information and purchase information about you to keep you updated of new features and product developments as well as to provide more relevant offers to you.


For report purposes

We use, process and/or analyze the Personal and/or Non-Personal Information we collect and/or are provided with to provide our Clients with anonymous marketing objective and strategy reports that may contain processed, populated (not raw, (directly or indirectly) identifying) data. Our Clients will not be able to identify our users in any way by using the data we provide to our Clients.


To develop, evaluate, improve and deliver our products and services

We use the Personal and/or Non-Personal Information we collect and/or are provided with to develop, evaluate, improve and deliver our product and services.

For example, if we learn from the information we collect and/or are provided with that certain retailers, certain gamification or certain Rewards scheme are valuable to Registered Users, we may offer more services or Rewards for those products.


Fulfill legal and regulatory requirements

We will not use and process your Personal Information unless required to comply with federal, state, or other applicable laws and regulations.


Protect the rights or property of SmartCart or our Registered Users

We also may use Personal and/or Non-Personal Information about you that we collect and/or provided with to the extent we believe it is necessary or appropriate to enforce or apply our rights under our agreements with Registered Users and/or to protect the rights, property or safety of SmartCart, our Registered Users and others.


How does SmartCart share information about you?

Anonymized Personal Information. We anonymized the data contained in users’ offline and online receipts to then proceed to analyze the data along with millions of other users. We share and monetize these anonymized data to our third-party clients that work with us under strict confidential agreement. The data we share to our third-party Clients can not be used to identify specific individual users.


Contests, sweepstakes and surveys

We may promote or offer contests, sweepstakes, similar promotional offers or surveys that may be co-sponsored by SmartCart and one or more other companies, or may be sponsored by anyone other than SmartCart. It is up to you if you want to join these contests or not.

Some or all the Personal and/or Non-Personal Information collected and/or provided with through these offers or surveys may be shared with the sponsor(s), Clients or other companies indicated on the entry form, in the governing rules or on the survey, as applicable. Your participation in such surveys indicates your acceptance of such terms.

We may also use and disclose personal information and/or data for purposes of announcing winners and beneficiaries of these contests and promotions.


Third-party companies

We may share anonymized and aggregated data that we collect and/or with which we are provided with third-party market research and other unaffiliated companies who may use, process and/or analyze the anonymized and aggregated data for any legally permissible purpose including but not limited to matching to additional data sets, data analysis and research reports.


Information we share with non-affiliated third parties as permitted by law

We reserve the right to disclose Personal and/or Non-personal Information about you to the extent permitted by applicable law, for example:


Business transfers

If there is a change of ownership in SmartCart’s business (whether by merger, sale of assets or otherwise), Personal and/or Non-Personal Information about you could be included as part of that transaction and could be used by the relevant counterparts.


Protection of SmartCart and others

We may display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you to third parties when we believe such action is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding.

We may also display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you as we believe appropriate to enforce or apply our rights under our agreements with Registered Users, and to protect the rights, property or safety of SmartCart, our Registered Users and others, including exchanging information for fraud protection and credit risk reduction.


With your consent

In addition to the above, we may display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you with others for purposes other than those set out elsewhere in this Privacy Policy, to the extent you consent to such action.


Non-Personal Information

We may provide aggregated Non-Personal Information about you to Clients, Partners or others for marketing, analysis and other purposes. For example, your purchase information may be aggregated with the purchase information of other Registered Users and analyzed to evaluate the effectiveness of certain award offers or advertisements, and the results of that analysis may be shared with Clients, Partners or others.


Security of Personal Information about You

SmartCart Group is committed to earning and keeping your trust. We understand the need for Personal Information about you to remain secure and private, and we have implemented security practices and procedures designed to safeguard Personal Information about you based on this Privacy Policy.

Only SmartCart employees and service providers who need to use, process and/or analyze Personal Information about you as part of their jobs are authorized to have access to Personal Information about you. Please remember that you also play a valuable part in data security. You should never share your Account password, if applicable, with anyone.

If you feel your password has been compromised, you should change it immediately. After you have finished using our mobile application or website(s), you should log out of your Account and exit your browser so that no unauthorized persons can use our website under your name or Account.


Online Forums

Please note that any Personal and/or Non-personal Information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. SmartCart is unable to control any use of such Personal and/or Non-Personal Information.


Collection of Information from Children

None of our products or services is intended for use and/or purchase by children, unless such use and/or purchase is done with a consent from one of the biological parents or legal guardian of the relevant child using the products or services.  If you are under the age of 18 or such younger age than the eligibility threshold to be deemed as an adult applicable in your jurisdiction, by ticking the consent box available on our mobile application and/or using our products or services, we assume that you have obtained a consent from one of your biological parents or legal guardian to use the mobile application and/or the products or services.


Changes to this Privacy Policy

Please note SmartCart reserves the right to modify and/or update this Privacy Policy from time to time so please review it frequently. We will post any Privacy Policy changes on this page and, we will provide a notice on the SmartCart mobile application or by email to the email address we have on file in your Account. Each later version of this Privacy Policy will override the previous version, and we will also store previous versions of this Privacy Policy that you may review upon your written request to us.


How to Contact Us

If you have any queries about our Privacy Policy, you may contact our Data Protection Officer at We will seek to attend to your request as best as we reasonably can.


Key Terms

Account – An “Account” is an account you establish with SmartCart.

Rewards – “Rewards” are the discounts, cash rebates, other cash rewards, points, coins, miles and/or other rewards that we offer you as a Registered User.

Cookies – A “cookie” is a small file containing a string of characters that is sent to your device when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

Non-personal Information – “Non-personal Information” is any information that is not Personal Information.

Personal Information – “Personal Information” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Registered User – A “Registered User” is an individual or entity that registers to receive any service provided by us, such as through our website or mobile application.

SmartCart or our website –  A “SmartCart website”, which may also be referred to as “our website”, is any website SmartCart or its affiliated companies host or otherwise operate.

Unsubscribe – To unsubscribe from all future email, click the unsubscribe link in the welcome email or any subsequent email from SmartCart. You may also email us at