Privacy Policy
SMART APPROACH CO., LTD. (“Smart Approach”, “we”, “our”, or “us”) respects your privacy and is committed to protecting personal data.
This Privacy Policy describes how we collect, use, process, and protect personal information in connection with our wireless communication and identity solutions, including RFID/NFC integration solutions, wireless charging integration solutions, Ultra-Wideband (UWB) integration solutions, customized antenna and RF connector solutions, digital ID cloud services, and OBM/ODM/OEM hardware development and manufacturing services, as well as integrations with digital wallet ecosystems such as Apple Wallet (VAS) and Google Wallet (Smart Tap).
By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy.
Information We Collect
We may collect and process the following categories of information:
(a) Personal Data
Personal data may include, but is not limited to:
- Full name and identification details
- Contact information (such as email address or phone number)
- Identity verification data, including credentials and supporting documentation
(b) Non-Personal Data
We may also collect non-identifiable information, including:
- Device information and identifiers
- System logs and interaction records
- Technical and usage-related data
(c) Automatically Collected Data
When users interact with our systems, we may automatically collect certain data, including IP address, timestamps, and authentication logs.
Purpose of Processing
Smart Approach processes collected information for the following purposes:
- To perform identity verification and authentication
- To issue, manage, and validate digital credentials
- To ensure system security and prevent fraud
- To operate, maintain, and improve our services
- To comply with legal and regulatory obligations
- To support OBM/ODM/OEM client coordination, including product development communication and order fulfillment
- To respond to inquiries submitted through our website contact channels
Legal Basis
Where required under applicable data protection laws, including the Personal Data Protection Act of Taiwan (「個人資料保護法」, PDPA) and, where applicable, the General Data Protection Regulation (GDPR), we process personal data based on one or more of the following legal grounds:
- Consent of the data subject
- Performance of contractual obligations
- Compliance with legal obligations
- Legitimate interests in maintaining secure identity infrastructure
Data Sharing and Disclosure
Smart Approach does not sell or rent personal data.
We may disclose personal information only under the following circumstances:
- To authorized partners, service providers, or relying parties for identity verification purposes
- To third-party platforms (such as Apple Wallet and Google Wallet) where necessary for service functionality
- To comply with applicable laws, regulations, or legal processes
- To protect the rights, safety, or property of Smart Approach or others
Third-Party Services
Our services may integrate with third-party platforms, including Apple Wallet (VAS), Google Wallet (Smart Tap), NXP MIFARE-compatible systems, ISO/IEC 18013-5 compliant Mobile Driver’s License (mDL) ecosystems, and other identity or access control platforms.
Such third parties operate under their own terms and privacy policies. Smart Approach does not control and is not responsible for the data practices of such third parties.
As our services evolve, we may integrate with additional identity ecosystem providers. Any material changes to such integrations will be reflected in updates to this Privacy Policy.
Data Security
Smart Approach implements appropriate technical and organizational measures to protect personal data, including but not limited to:
- Encryption of data in transit and, where applicable, at rest
- Access control and authentication mechanisms
- Secure certificate and key management systems
- Monitoring and audit procedures
Notwithstanding the foregoing, no method of transmission or storage is completely secure, and absolute security cannot be guaranteed.
Data Retention
Personal data will be retained only for as long as necessary to fulfill the purposes set forth in this Privacy Policy, including:
- Identity verification processes
- Credential lifecycle management
- Compliance with legal or regulatory requirements
Data may be deleted, anonymized, or securely archived when no longer required.
User Rights
Subject to applicable laws, individuals may have the right to:
- Request access to their personal data
- Request correction of inaccurate data
- Request deletion of personal data
- Withdraw consent (where applicable)
- Object to or restrict processing
Requests may be submitted using the contact information provided below.
Cookies and Tracking Technologies
Smart Approach may use cookies or similar technologies to:
- Facilitate authentication processes
- Enhance user experience
- Support system security
Users may control or disable cookies through their browser settings.
B2B Client and Business Contact Data
Smart Approach primarily serves business clients, including OBM/ODM/OEM partners and enterprise customers. In the course of such business relationships, we may collect and process business contact information, such as the name, title, email address, and telephone number of corporate representatives. Such information is used solely for the purposes of business communication, project coordination, and order fulfillment, and is not used for direct marketing without consent. Business contact data collected through our website contact form (https://www.smart-approach.com.tw/聯絡我們/) is processed in accordance with this Privacy Policy.
Personal data may be processed or transferred to jurisdictions outside the user’s country or region where necessary for service operation, integration support, or infrastructure management.
Smart Approach will take reasonable steps to ensure that such transfers comply with applicable data protection requirements.
Changes to This Privacy Policy
Smart Approach reserves the right to modify this Privacy Policy at any time. Any changes will be effective upon posting the updated version on our website.
Contact Information
If you have any questions regarding this Privacy Policy or our data practices, please contact:
SMART APPROACH CO., LTD.
Email: service@smart-approach.com.tw
Website: https://www.smart-approach.com.tw/
Address: 3F-5, No. 1, Taiyuan 2nd Street, Zhubei City, Hsinchu County 302, Taiwan (R.O.C.)
Tel: +886-3-5601363
Fax: +886-3-5601361
