SmartDeer Global Privacy Policy

Last Revised: August 28, 2025

SmartDeer (IDEAL-CAREERBRIDGE HOLDINGS (HK) LIMITED, hereinafter referred to as “we” or “SmartDeer”) is committed to providing compliant and efficient human resource management services to enterprises worldwide. We firmly believe that data security and privacy protection are the foundation of our services. Regardless of your location, SmartDeer promises to protect your personal information with consistently high standards. When SmartDeer is mentioned in this policy, it refers to the relevant SmartDeer entity that has entered into an agreement with you, where applicable.

This policy is intended to explain how we collect, process, and disclose your information. This Privacy Policy forms part of the SmartDeer Platform Terms of Service. The terms used herein are consistent with the definitions in the Terms of Service and the Appendix to this Policy.

I. Scope of Application

This Privacy Policy applies to the following individuals:

1. Job seekers and applicants;
2. Registered users of the SmartDeer community;
3. Entities or individuals supplying goods or services to SmartDeer;
4. Visitors to the SmartDeer website who have not entered into a contract;
5. SmartDeer’s corporate clients and their representatives or ultimate beneficial owners;
6. Freelancers or independent contractors cooperating with us through the platform;
7. Participants in activities, surveys, or meetings organized by SmartDeer;
8. Prospective users interested in becoming clients.

By using our website and/or our services, or by interacting with SmartDeer in any way, you agree to our collection and use of your information in accordance with this Privacy Policy.

II. Information Collection

The following table lists the types of personal information we may collect and use about you. This information may be used alone or in combination with other information to identify you (“Personal Information”).

Information Type	Examples of Specific Content
Contact Information	Phone number, email, address
Identity Verification	Name, identification documents, date of birth, selfie
Financial & Payment	Bank card, payment account, transaction details
Device & Technology	Device model, IP, browser, operating system
Location & Behavior	Country, city, IP location, payment location
Employment & Education	Work experience, education, certificates
Public & Third-Party Data	Public records, credit information, data provided by partners
Preferences & Consent	Your authorizations, choices, settings
Community & Interaction	Content, comments, files you post in the community
Biometric	Photos or document images used for identity verification
Other Voluntary Information	Surveys, feedback, etc. you voluntarily provide

For the avoidance of doubt, personal information does not include any data that has been anonymized and from which identifying elements have been destroyed. SmartDeer may also collect and use non-personal information to analyze the effectiveness of our services and improve them. We may collect non-personal information through our services, website, and cookies.

III. Sources of Personal Information

We may collect personal data about you or your business from any of the following sources:

1. Information you provide directly: registration, filling out forms, contacting customer service, participating in activities, uploading files, etc.;
2. Information collected automatically: when you visit the website or app, the system automatically records device, behavior, cookies, and other data;
3. Information from third parties: partners, service providers, public databases, social platforms, government agencies, etc.

IV. Cookie Policy

This Cookie Policy details our use of cookies and other similar tracking technologies on this website. We highly value your privacy and are committed to transparency in data collection and use. By using our website, you agree to the use of cookies as described in this policy.

(I) What is a Cookie?

A cookie is a small file stored on your device by a website, used to remember your preferences, enhance your experience, and analyze your behavior.

(II) How We Use Cookies

We use cookies to:

1. Ensure the basic functionality of the website;
2. Count visits and usage patterns;
3. Remember your settings and preferences;
4. Analyze and optimize our services;
5. Support third-party advertising and analytics tools.

(III) Third-Party Cookies

We may also use third-party cookies to collect statistical information related to your use of this website. These cookies are intended to analyze and optimize website performance and user experience. The information collected is aggregated and does not identify you personally.

(IV) Managing Your Cookies

You can choose to allow, refuse, or delete cookies in your browser or via our cookie pop-up. However, disabling cookies may affect some features.

If you choose to clear all cookies, your relevant data and personalized settings on this website may be lost, including the function to disable cookies itself. This is because the function to disable cookies requires storing a cookie on your device, and clearing all cookies will render this function inoperative.

(V) Cookie Consent

Our cookie banner allows you to express your consent to the use of cookies and adjust your cookie preferences.

You may withdraw your consent to the use of non-essential cookies at any time via the cookie banner.

You may also refuse the use of non-essential cookies.

(VI) Other User Tracking Technologies

We may also use pixel tags, web beacons, and similar technologies to collect access and marketing data. These are usually used in conjunction with cookies.

V. Purposes of Information Use

The following table lists the purposes for which we may use your personal information, as well as the legal bases for processing as required by applicable data protection laws:

Purpose	Legal Basis	Applicable Subjects
Performance of contracts, provision of services	Performance of contract	Individuals, clients, contractors, suppliers
Service optimization, operational efficiency	Performance of contract, legitimate interests	Visitors, clients, contractors, community members, suppliers, prospective clients
Identity verification, service security	Performance of contract, legitimate interests, consent	Clients, contractors
Marketing, event notifications, personalized content	Consent, legitimate interests	Visitors, clients, contractors, community members, prospective clients, event participants
Recruitment and talent evaluation	Performance of contract, legitimate interests	Candidates
Platform and service security maintenance	Legitimate interests, legal obligations, performance of contract	All users
Service change notifications, customer support	Performance of contract, legitimate interests	All users
Business management, payments, account management	Performance of contract, legitimate interests	Clients, contractors, suppliers
Compliance with laws, tax reporting	Legal obligations	Clients, contractors, suppliers
Community platform maintenance	Performance of contract, legitimate interests	Community members
Aggregated anonymized data for analysis and research	Consent, performance of contract, legitimate interests	Employees

If you refuse to provide information required for the performance of a contract or by law, we may not be able to provide you with relevant services.

VI. Sharing Information with Third Parties

Unless otherwise stated, we only share your information with the following third parties for the purposes described above under “Purposes of Information Use”:

1. Clients you serve;
2. Trusted third-party agents, partners, and service providers (such as website hosting, IT, payment, legal, audit, etc.), who may only use your information for contractually agreed purposes and are required to maintain confidentiality;
3. Government, law enforcement, and regulatory agencies, as required by law or to protect the business, users, and public safety;
4. Third parties in the event of business mergers, acquisitions, etc.;
5. Academic institutions (only de-identified information, subject to confidentiality agreements);
6. The public (only anonymized, aggregated statistical data);
7. SmartDeer affiliates (who use information in accordance with this policy);
8. Third-party advertising partners (such as social platforms, for targeted advertising);
9. Other third parties with your consent.

We promise: We will never sell your personal information.

VII. Retention of Personal Information

We retain your personal data only for as long as necessary to achieve the purposes for which it was collected and in compliance with applicable legal requirements. The retention period depends on the amount, nature, sensitivity, and purpose of the data. We regularly assess whether it is necessary to continue retaining data.

VIII. Communication and Notifications

We may send you newsletters or marketing information. You may opt out of receiving such communications at any time via the unsubscribe link in our emails or by contacting us. Even if you opt out of marketing communications, we may still send you service-related notifications.

IX. International Transfers

Our business operations span the globe, and we comply with legal requirements regarding cross-border data transfers. With your consent, we may transfer your personal information to other SmartDeer group subsidiaries or third parties worldwide for the purposes described in this Privacy Policy. Wherever we transfer, store, or process your personal information, we will take reasonable measures to protect its privacy. These measures may include implementing legally recognized standard contractual clauses, obtaining your consent, or other lawful means of transfer.

X. Third-Party Advertising, Links, and Content

This platform may contain links to third-party websites. Third parties (such as advertising networks) may collect information about your online activities through cookies, pixels, and similar technologies for interest-based advertising. We have no control over the content or privacy policies of third-party websites and recommend that you review their policies when visiting.

We only process relevant information with your consent or based on legitimate interests. You may object to our use of your data for direct marketing at any time as described in the “Your Rights” section.

XI. Children’s Privacy

We do not knowingly collect personal information from individuals under the age of 18. If you are a parent or guardian and discover that your child has provided us with information, please contact us promptly. If we discover that we have collected information from a minor without verifiable parental consent, we will delete it as soon as possible.

XII. Your Rights

Depending on applicable privacy laws, you may have the following rights:

1. Obtain a copy of your personal information and information about its processing;
2. Correct inaccurate information;
3. Delete information that is no longer needed;
4. Restrict processing;
5. Object to processing based on legitimate interests;
6. Object to automated decision-making;
7. Obtain portable data or transfer it to a third party;
8. Withdraw consent (where applicable);
9. Lodge a complaint with a data protection authority.

To exercise these rights, you may contact us at support@smartdeer.work.

Before disclosing the information you request, we may ask you to provide additional information to verify your identity and ensure information security. If you wish to make a request on behalf of another person, you must provide proof of authorization. We reserve the right to charge a fee where permitted by law. We may refuse requests that could endanger the privacy of others, are excessively burdensome, or would require us to take actions not permitted by applicable law. In addition, as required by law, we may need to retain certain personal information for a limited period for record-keeping, accounting, and fraud prevention purposes. Please note that you may be able to exercise some rights without our intervention. For example, if you are a registered user of the SmartDeer platform, you can access and update your personal data yourself.

XIII. Security

We take your information security seriously and implement multiple measures to prevent data loss, misuse, unauthorized access, disclosure, alteration, or destruction. Only employees, agents, and contractors who are authorized for business purposes may access your data, and all are bound by confidentiality obligations.

If you set a password or credentials to access the platform, please keep them secure and do not share them with others. Please note that no method of transmission over the Internet or electronic storage is completely secure. If you discover a security vulnerability, please contact us immediately at support@smartdeer.com.

XIV. Changes to the Privacy Policy

This Privacy Policy is effective as of the “Last Revised” date at the top of this policy and will remain in effect unless any changes are made in the future, which will take effect immediately upon posting on this page.

We reserve the right to update or change our Privacy Policy at any time. You should review this Privacy Policy periodically. Your continued use of the service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If you have any questions or concerns about privacy when using our services, please contact us at support@smartdeer.work.

XV. Regional Supplementary Terms

SmartDeer is committed to global compliance. The following are specific privacy terms that may apply to your region and supplement the general terms of this Privacy Policy:

(I) Brazil

1. Legal Basis
   If you are a resident of Brazil, we only collect and process your information to the extent permitted by applicable law. For information on the legal bases we rely on when processing your personal information, please refer to the “Purposes of Information Use” section of this Privacy Policy.
2. Your Privacy Rights
   We assure you that you will not be discriminated against for exercising your rights. If you are a resident of Brazil, in addition to the rights set out in the “Your Rights” section of this Privacy Policy, you also have the right to request the anonymization of your personal information and to obtain information from public and private entities with whom we have shared your personal information.

(II) China

1. Legal Basis
   If you are a resident of the People’s Republic of China, we only collect and process your information on a lawful basis as permitted by applicable law. For details on the legal bases under the Personal Information Protection Law of China, please refer to the “Purposes of Information Use” section of this Privacy Policy.
2. Your Rights under the Personal Information Protection Law (“PIPL”)
   If you are a resident of the People’s Republic of China, in addition to the rights set out in the “Your Rights” section of this Privacy Policy, you also have the right to access, correct, and delete the personal information of your deceased close relatives in accordance with the Personal Information Protection Law of China.
3. Cross-Border Data Transfers
   SmartDeer will transfer your personal information to Hong Kong, China, as described in the “International Transfers” section of this Privacy Policy. SmartDeer may also transfer your personal information to third parties outside of China as necessary for the purposes described in the “Purposes of Information Use” section. Before transferring your personal information outside of China, we will ensure that all requirements under Chinese laws and regulations regarding cross-border data transfers are met and require overseas recipients to provide a level of protection for your personal information that is no less than that required by applicable Chinese laws and regulations.

(III) Japan

1. Legal Basis
   If you are a resident of Japan, we only collect and process your information on a lawful basis as permitted by applicable law. For details on the legal bases under the Act on the Protection of Personal Information of Japan, please refer to the “Purposes of Information Use” section of this Privacy Policy.
2. Your Rights under the Act on the Protection of Personal Information (APPI)
   If a data breach occurs, or if SmartDeer believes that such a breach may have occurred at us or our service providers, SmartDeer will promptly inform you of the relevant facts, conduct an investigation and report the results, and implement preventive measures to prevent recurrence. SmartDeer will also provide necessary and appropriate supervision of employees, such as education or training for those handling information.
3. Cross-Border Data Transfers
   Before transferring your personal information outside of Japan, we will ensure that all requirements under Japanese laws and regulations regarding cross-border data transfers are met and require overseas recipients to provide a level of protection for your personal information that is no less than that required by applicable Japanese laws and regulations.

(IV) Thailand

1. Legal Basis
   If you are a resident of Thailand, we only collect and process your information on a lawful basis as permitted by applicable law. For details on the legal bases under the Personal Data Protection Act of Thailand, please refer to the “Purposes of Information Use” section of this Privacy Policy.
2. Your Privacy Rights
   Under the current personal data protection laws of Thailand, you have the following rights: to withdraw your prior consent to the collection, use, and disclosure of your personal data; to access your personal data; to obtain your personal data (including requesting it in a format readable or usable by automated tools or devices), or to transfer it to another data controller; to object to our collection, use, or disclosure of your personal data; to request deletion or anonymization of your personal data; to request suspension of the use of your personal data; to restrict the use of your personal data; to correct, update, or supplement your personal data; and to lodge a complaint with the Personal Data Protection Committee of Thailand if you discover any violation of applicable Thai data protection laws.

XVI. Appendix

The terms used in this Privacy Policy are defined as follows:

1. Account: Refers to an account used to access and use the platform in accordance with applicable terms.
2. Administrator: Refers to a user who applies for an account on behalf of an enterprise, accesses services, manages the account, and otherwise acts on behalf of the enterprise.
3. Enterprise: Refers to any type of legal entity that creates an account on the platform and is managed by an administrator.
4. Client: Refers to a user who requests services through the platform and pays for any services received through the platform.
5. Content: Refers to all content provided on or through the platform or services, including any documents, images, photos, pictures, videos, data, audio, or text, as well as any modifications or derivative works thereof.
6. Contractor: Refers to an entity that provides and performs the services described in the contract to the client and receives payment from the client through the platform.
7. Payment Service Provider: Refers to a third-party financial service provider related to user payments.
8. User: Refers to any individual authorized to access an account.
9. User Content: Refers to all information content provided by users through the platform or services.