Privacy Policy

1. Introduction

Welcome to Smartly, a digital compliance platform developed by Faber Ops Pte. Ltd., a Singapore-based company doing business as Aquila ("Aquila", "we", "our", or "us").

Smartly assists organizations in organizing, preparing, and managing data to support internal and third-party compliance processes.

We understand that you are aware of and care about your own personal privacy interests, and we take that matter seriously. This Privacy Policy describes our policies and practices regarding our collection, storage, use, transfer and deletion of your Personal Data, and sets forth your privacy rights. We ensure the processing of your Personal Data is in compliance with all data protection applicable laws.

Throughout this Privacy Policy, "Personal Data" shall mean all the data which, by using our website or products, you are allowing us to collect, store, use and transmit, about you or your company.

2. Data Collection

Aquila collects various types of data necessary for providing and improving its services, including the Personal Data you provide when registering, engaging with its services, or contacting them.

This information includes, but is not limited to:

• Name
• Company information
• Contact details
• Employment information

From time to time, we may receive Personal Data from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your Personal Data from a third party's website (e.g. LinkedIn).

3. Use of Smartly

As is true of most other websites, Aquila's website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our website.

We use this information to help us design our site to better suit our users' needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

4. International Data Sharing

In providing its services, Aquila may transfer your Personal Data to third parties in other countries for processing. Before any such transfer, we will ensure compliance with applicable laws and implement appropriate safeguards, such as contractual, technical, and organizational measures.

A list of our third party sub processors:

• Amazon Web Services. Purpose: Infrastructure Hosting; Location: Singapore
• Google. Purpose: Support Ticket Email Processing; Location: Singapore
• Sentry. Purpose: Application Error Tracking; Location: US
• Slack. Purpose: Internal Communications; Location: US
• HubSpot. Purpose: Sales & Marketing Analytics; Location: US
• PostHog. Purpose: Product Analytics & Monitoring; Location: US, EU, Self-hosted
• Cloudflare. Purpose: CDN / Security / Hosting; Location: Global (logs in US)
• GitHub. Purpose: Version Control / DevOps; Location: US, EU (via Copilot servers)
• OpenAI. Purpose: AI / GenAI Processing; Location: US

5. Data Subject Rights

You are provided certain rights related to your Personal Data, including:

• Right to be informed: If you wish to confirm that we are processing your Personal Data, or to have access to the Personal Data we may have about you, please contact us.
• Right of access: You may request information about the purpose of the processing; the categories of Personal Data concerned; who might have received the data from us; what the source of the information was; and how long it will be stored.
• Right to rectification: You have a right to rectify the record of your Personal Data we maintain if it is inaccurate.
• Right to erasure and right to restrict processing: You may request that we erase your Personal Data or cease processing it, subject to certain exceptions.
• Right of data portability: You can request that the Personal Data you provided be given to you in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to our processing of your Personal Data if it is based on legitimate interests.

6. Data Storage and Retention

Aquila stores your Personal Data on the servers of a cloud-based database management service supplier located in Singapore. We retain service data for the duration of the customer's business relationship with us and for a period of time thereafter, to analyze the data for our own operations, and for historical and archiving purposes associated with our services.

For more information on where and how long your Personal Data is stored, please contact us at: [email protected].

7. Security

Aquila endeavors to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with the relationship they have with you, and the practices described in this Privacy Notice. We also enter into data processing agreements and model clauses with our vendors whenever feasible and appropriate.

8. Changes to this Privacy Policy

This policy entered into force on 1st June 2025. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new Personal Data practices or adopt new privacy policies. Please review it periodically.

9. Data Protection Officer ("DPO")

Aquila has appointed an internal DPO for you to contact if you have any questions or concerns about our Personal Data policies or practices.