Last modified: February 2026

1. Background

This website [smartstate.com], its subdomains and its related features (“Website”, collectively, the “Services”) are operated by SmartState ("we", "us", "our" or "Company”) that provides this Privacy Notice ("Notice") to give you a better understanding of our practices regarding the collection, use, transfer, storage and other processing of Personal Data (as defined below) we collect about website visitors, and job applicants ("you", "your ") and the reason why we collect such data, the manner in which we process this data, the entities with whom we share the said Personal Data, your rights in relation to the collection, processing and sharing of such data and any other pertinent matter relating to privacy and security of your Personal Data. 

We understand that your privacy is important to you and that you care about how your Personal Data is used, processed and shared. We respect and value the privacy of everyone who visits our website or otherwise interacts with us and will only collect and use Personal Data in ways that are described in this Notice.

Please read this Notice carefully and ensure that you understand it. Note that this Notice does not form part of any contract of employment or other contract to provide services.

If you do not agree to this Notice, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this Notice and our Terms. 

You are not legally required to provide us with any Personal Data (as defined below), but without it we will not be able to provide you with the best experience of using our Services.

Specifically, this Notice describes the following:

1. Background
2. Categories of Personal Data We Collect
3. Purposes of Processing Personal Data
4. Who We Share Your Personal Data With
5. Cookies and Tracking Technologies
6. Your Rights
7. Authorized Agents
8. Data Retention
9. Transferring Your Personal Data
10. Minors
11. How We Protect Your Personal Data.
12. Contacting Us
13. Changes to Our Privacy Notice

2. Categories of Personal Data We Collect 

We collect Personal Data about you, meaning any information which potentially allow your identification with reasonable means (for example, email address or name, collectively “Personal Data”). This section sets out how and when we collect and process Personal Data about you.

• Employment and qualifications data - This type of data may include your full name, your employment history, your education and qualifications, your age and gender, diploma, letter of termination from previous employer original rental agreement or any title of ownership, tax clearance, and any other data pertinent to your evaluation as a prospective employee, recruitment agencies' reports, letters offering and accepting employment, emergency contact information, interview notes and recommendation checks. We obtain this data from you when you contact us, either by submitting your CV, using the contact form on the website or by other means (i.e., past employers, social media platforms such as LinkedIn or recruitment and screening agencies). We may also obtain such data from third parties (references you provide) and open sources. In those circumstances, the Company will take reasonable steps to ensure that those third parties have represented to us that they have the right to disclose the Personal Data to us.
• Website activity and technical data - This type of data may include your activity on the website, the pages you visit, the links you click on, and other similar activities, traffic data, GeoIP location, information from your browser, computer or mobile device when you access or use our website, device and network information.
• Other information you provide to us - This includes any other data you choose to share with us 

Sensitive Personal Data – Where applicable, this could include any medical history, health or sickness records you provide us with, information about criminal convictions and offences and any other information required by law to be provided by you in order to complete your employment process. We will only process such information, as well as disclose it to competent authorities (law enforcement bodies), where it is strictly necessary and required for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act; (ii) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes; (iii) managing the recruitment process and job application, in particular when applying for an employment authorization for foreign nationals.

We do not perform any automated decision making or profiling using your Personal Data.

We do not “Sell” or “Share” Personal data about you, as these terms are defined under applicable U.S. privacy laws.

3. Purposes of Processing of Personal Data

• Managing candidate applications and recruitment process.
• Answering to business inquiries and customer support requests.
• Security reasons, including ensuring the security of company-held information, company's systems, detecting fraudulent or illegal behavior, background checks through KYC and reference check set.
• Complying with applicable laws, including contractual due diligence and judicial or administrative orders regarding individual candidates.
• Evaluating the outreach and performance of our website.
• Conducting due diligence of the Company's activities (in particular, recruitment and employment activities) in the event of a third party contemplating the purchase or investment in the Company;
• Handling legal disputes. If the Company receives a notice of legal proceedings for actions taken by a candidate or customer in the context of any dispute, claim, suit, demand or legal proceedings, if any, between you and the Company.

If there are circumstances where the Company considers it needs to process Personal Data for purposes that are not compatible with the purposes above, we will provide you with an updated notification regarding such new purpose (or seek your express consent where applicable and if necessary).

4. Who We Share Your Personal Data With?

We may share your Personal Data with competent authorities having jurisdiction over us. Such disclosures will only be made when permitted or required pursuant to applicable data protection laws and/or other legislation applicable to us.

We may share your Personal Data with other companies in our corporate group – our parent companies, subsidiaries, and sister companies. These companies shall process your Personal Data on our behalf on the grounds and for the purposes listed in this Notice. We may share your Personal Data with other selected third parties, including inter alia:

• Third party service providers: IT and related services’ providers and their sub-processors, such as service providers contracted to store your Personal Data (e.g., cloud providers), human resource information system or human resource management system, enterprise resource planning and record management tools, payroll providers (upon successful admission as a company employee);
• Affiliated companies and business partners;
• Recruitment agencies: for the purpose of recruitment and assessing your fitness for a specific role;
• Business transactions: we may share your Personal Data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Notice;
• Governmental authorities and regulatory bodies: to meet local statutory requirements e.g., tax authorities, regulatory registration bodies, etc., such as with governmental agencies and authorities and regulators, social organizations, courts and other tribunals, to the extent permitted or required by applicable law;
• External advisors: our lawyers, advisors, auditors, consultants who we may engage from time to time to advise on any matter which requires them to gain access to Personal Data.

These third-party service providers may have access to your Personal Data as needed to perform their functions, but they are not permitted to use it for other purposes. To ensure your Personal Data is secured, the Company exercises appropriate due diligence in the selection of such service providers and where applicable enters into contractual agreement requiring such service providers to maintain adequate technical and organizational security measures to safeguard the Personal Data, and process the Personal Data only as instructed by the Company (as applicable).

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance site functionality, measure performance, and support personalized advertising. Some cookies are strictly necessary, while others require your consent. Our cookie banner allows you to accept or decline non-essential cookies.

6. Your Rights

 Depending on the jurisdiction in which you reside and subject to the applicability of data protection regulations to us, you may have certain rights regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, please contact us at [hr@smartstate.com] for more information, or to exercise the following rights.

• Right to access: You have the right to be informed about our processing and use of your Personal Data and the right to access your Personal Data we process;
• Right to correct: You have the right of rectification if any of your Personal Data we process is inaccurate or incomplete;
• Right to delete: You have the right to be forgotten – i.e. the right to ask us to delete your Personal Data we process;
• Right to limit use and disclosure of your sensitive Personal Data: You have the right to restrict the processing of your Personal Data, and the right to object to us using your Personal Data for particular purposes, e.g. for marketing purposes;
• Right to data portability: Data You have the right to data portability (obtaining a copy of your Personal Data to re-use with another service or organization). We will provide such copy free of charge unless the request is manifestly unfounded or excessive, where in such case a reasonable fee for administration costs may be charged;
• Right to opt-out of the sale or share of Personal Data: In the event that we sell or share your Personal data for behavioral advertising purposes, you may have the right to submit a request to opt-out of the sale or share of your Personal data.
• Right to non-discrimination: The right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
• Right to appeal a denial of your request: If we deny your request, you have the right to submit an appeal for a second review. Instructions for submitting an appeal will be provided in response to your original request. The appeal request shall be submitted to [hr@smartstate.com] or using the contact details specified in the "Contact Us" section in the Privacy Notice.

Kindly note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. Where applicable, Company will respond to your request within the timeframe prescribed by applicable laws and regulations from the date received, and extension times may apply based on jurisdiction. In addition, in certain instances, your Personal Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. 

In addition, note that you are responsible for updating the Company if there are any changes or inaccuracies in your Personal Data. You may exercise these rights by contacting us at [hr@smartstate.com]. Where required by applicable laws and regulations, we will handle these requests. In some jurisdictions, you have the right to appeal a rejection of your request. The appeal request shall be submitted to [hr@smartstate.com], or using the contact details specified in the “Contact Us” section in this Notice. If your appeal is denied, certain jurisdictions allow you to submit a complaint via the local attorney general or another competent authority responsible for handling such matters.

If you think we have infringed data protection laws, you can file a claim with the relevant authority in your jurisdiction of residency, as applicable to you.

7. Authorized Agents

If you are a California resident, you may only designate an authorized agent to make a request on your behalf if: (i) The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf. The request must: (i) provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you, and (ii) describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

8. Data Retention

We do not process your Personal Data for any longer than is necessary for the purposes of processing for which it was first collected, except as otherwise permitted or required by applicable law or regulatory requirements. Your Personal Data will be retained for as long as we have a relationship with you (for example, evaluating employment opportunity, provision of our KYC or answering your queries). To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

9. Transferring Your Personal Data

We may be required to transfer your Personal Data to service providers, authorities and affiliates in jurisdictions that are outside the US. In these instances and where applicable, the Company is taking ongoing measures to ensure that such service providers and affiliates have implemented appropriate safeguards to protect the security of Personal Data. This includes, where applicable, entering into agreements with such service providers. Your Personal Data will never be shared with third parties for their own marketing purposes unless you give your explicit consent thereto).

10. Minors 

We do not knowingly collect Personal Data from Minors (as determined under the applicable laws where the individual resides; “Minors”). By accessing or using our Services, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.

11. How We Protect Your Personal Data

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your Personal Data is protected by robust safeguards to ensure secured processing. For example, we ensure Personal Data is encrypted both in transit and at rest, and any access is strictly limited to a minimum number of authorized individuals who are subject to confidentiality commitments.  

We will take all steps necessary to ensure that your Personal Data is treated securely and in accordance with this Notice. However, please note that the transmission of Personal Data via the internet is not completely secure.

12. Contacting Us

If you have any questions about this Notice, please contact us by email at [hr@smartstate.com]. Please ensure that your query is clear, particularly if it is a request for information about the data we process.

13. Changes to Our Privacy Notice

We may change this Privacy Notice from time to time. You are advised to check for updates regularly. Please note that changes will be immediately posted on the website and will be deemed to have been accepted on your first use of the website following the alterations in the Privacy Notice. We recommend that you check this page regularly to remain up to date with any changes, and where appropriate, we will also notify you by e-mail.