Personal Data
In this Privacy Policy, “Personal Data” refers to any data about an individual who can be identified from that data and “Act” refers to the Personal Data Protection Act, 2010 (as amended).
Examples of such Personal Data you may provide to us include your name, telephone numbers, mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

Collection of Personal Data
Generally, Smart Holidays collects Personal Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our mobile app platform or website in the following ways:

  • when you submit a form for registering as a customer on our website or any other forms relating to any of our Products and Services
  • when you interact with our customer service team, for example, via telephone calls, letters, face-to-face meetings and emails
  • when you request that we contact you, be included in an email or other mailing list
  • when you respond to our promotions, initiatives or to any request for additional Personal Data
  • when you are contacted by, and respond to, our marketing representatives and customer service team
  • when we receive references from business partners and third parties, for example, where you have been referred by them
  • when you submit your Personal Data to us for any other reasons

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.

Purposes for the Collection, Use and Disclosure of Personal Data
Smart Holidays collects, may use and disclose your Personal Data for the following purposes:

  • responding to your queries and requests;
  • managing the administrative and business operations of Smart Holidays and complying with internal policies and procedures;
  • facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving Smart Holidays or any of its related corporations;
  • matching any Personal Data held which relates to you for any of the purposes listed herein;
  • resolving complaints and handling requests and enquiries;
  • preventing, detecting and investigating crime and analyzing and managing commercial risks;
  • providing media announcements and responses;
  • monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
  • organising promotional events;
  • legal purposes (including but not limited to obtaining legal advice and dispute resolution);
  • conducting investigations relating to disputes, billing or fraud;
  • meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Smart Holidays (including but not limited to responding to regulatory complaints, disclosing to
  • regulatory bodies and conducting audit checks, due diligence and investigations); and
  • purposes which are reasonably related to the aforesaid

Where permitted under the Act:
Smart Holidays may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

  • analytics and tracking,
  • providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from Smart Holidays;
  • matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by Smart Holidays;
  • leads generation and management for marketing Smart Holidays’s Products and Services;
  • communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing);
  • organising promotional events and corporate social responsibility projects; and
  • purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Smart Holidays’s Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Smart Holidays.

If you have provided your telephone numbers, Smart Holidays may contact you using such telephone numbers (including via voice calls, messenger, sms, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts, flash sales and special offers).

In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
Should you wish to withdraw your consent for us to send you sales, marketing or promotional information via a specific mode, please inform us as follows:

  • to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
  • to withdraw consent from receiving promotional material with your order package: please email customer service, with the words “PERSONAL DATA” in the subject line, at the address provided below.

Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Smart Holidays.

Disclosure of Personal Data

Smart Holidays will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

  • Smart Holidays’ related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
  • companies providing services relating to insurance and consultancy to Smart Holidays;
  • agents, contractors or third party service providers who provide operational services to Smart Holidays, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Smart Holidays;
  • vendors or third party service providers in connection with marketing promotions and services offered by Smart Holidays or its preferred partners;
  • commercial shops and retailers in relation to providing rewards and benefits;
  • any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
  • our professional advisers such as auditors and lawyers;
  • relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
  • any other party to whom you authorise us to disclose your Personal Data to.

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Contacting Us
For any questions relating to your Personal Data or about our Privacy Policy, you may contact our Data Privacy Officer by email at:

Governing Law
This Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Malaysia.