Last updated: 12 November 2026
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal data. It also explains your rights in relation to your personal data and how to contact us or the Data Protection Board of India if you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the laws of India, including the Digital Personal Data Protection Act, 2023 (the “DPDP Act”), the Information Technology Act, 2000 and the rules made under them, and we are the “Data Fiduciary” for that personal data. Where the General Data Protection Regulation of the European Union or the United Kingdom applies to you, we are also the “controller” for the purposes of that law.
1. Key terms
| We, us, our, SmartCirqls, or the Company | SmartCirqls Infotech Private Limited (CIN U72300MH2012PTC228942), 1206, 12th floor, Marathon NextGen Icon, Off G.K. Marg, Lower Parel (W), Mumbai 400013, India, and its affiliates |
|---|---|
| Personal data | Any data about an individual who is identifiable by or in relation to such data |
| Platform | Our website at www.smartcirqls.com, and our related products, services, information and communications |
| You, Data Principal | The individual to whom the personal data relates |
2. Personal data we collect about you
We may collect and use the following personal data:
| Category of personal data | Specific types collected |
|---|---|
| Identity and contact details | Name, job title, company, email address, phone number and postal address that you give us when you contact us, become a customer or apply for a job. |
| Communications | The content of emails, calls and messages you exchange with us, including enquiries about our products, services and telecom short codes. |
| Commercial information | Records of products and services you have bought from us, considered, or enquired about, and related contracts and invoices. |
| Recruitment information | Your CV and the information in it, if you apply for a role. |
| Technical information | Internet Protocol (IP) address, browser type, the pages you request and the time of your visit, which our web servers may record for security and troubleshooting. |
Some of this personal data is needed to provide products and services to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing products or services to you.
3. Cookies and similar technologies
This website does not use advertising, analytics or tracking cookies. It stores one setting in your browser's local storage: whether you chose the light or dark colour theme. This stays on your device, is not sent to us, and you can clear it at any time in your browser settings. Our fonts and images are served from our own servers.
If we introduce analytics or other tracking technologies in future, we will update this policy before doing so and, where the law requires it, ask for your consent.
4. How your personal data is collected
We collect most of this personal data directly from you: by phone, email, in meetings, through your orders, or when you visit our website. We may also collect personal data:
- From publicly accessible sources, such as company registries and professional networking sites;
- From third parties with whom you have asked us to work, or who introduce you to us, such as your employer or a business partner;
- Automatically when you use the Platform, as technical information recorded by our web servers; and
- Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, and email.
5. How and why we use your personal data
Under the DPDP Act, we can only use your personal data for a lawful purpose and on a lawful ground, which is either:
- your consent, which you may withdraw at any time; or
- a legitimate use permitted by the DPDP Act, for example where you have voluntarily given us your personal data for a specified purpose (such as asking us for a proposal), or where we must process it to comply with the law or a court order.
The table below explains what we use your personal data for and on what ground:
| What we use your personal data for | Our ground |
|---|---|
| To respond to your enquiries and provide products and services to you | Legitimate use: you voluntarily provided the data for this purpose; performance of our contract with you |
| To prevent and detect fraud against you or SmartCirqls | Legitimate use; compliance with law |
| Conducting checks to identify our customers and verify their identity, including checks required for telecom services | Compliance with law and regulatory obligations |
| Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, and gathering information for audits, enquiries or investigations by regulatory bodies | Compliance with law and regulatory obligations |
| Ensuring business policies are followed, e.g. policies covering security and internet use | Legitimate use: maintaining the security of our systems and the data we hold |
| Ensuring the confidentiality of commercially sensitive information, and preventing unauthorised access to and modification of our systems | Legitimate use; compliance with law |
| Updating and enhancing customer records | Performance of our contract with you; compliance with law |
| Statutory returns, external audits and quality checks | Compliance with law and regulatory obligations |
| Considering your application for a role | Legitimate use: you voluntarily provided your CV for this purpose |
| Marketing our products and services to existing and former customers and to people who have expressed an interest in them | Your consent, where required; otherwise legitimate use where you have given us your details for this purpose |
6. Promotional communications
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including new products and offers. Where consent is needed, we will ask for it separately and clearly. We will always treat your personal data with the utmost respect.
You have the right to opt out of receiving promotional communications at any time by contacting us at info@smartcirqls.com or using the “unsubscribe” link in our emails or the “STOP” instruction in our text messages.
7. Who we share your personal data with
We may disclose aggregated information that does not identify any individual or device without restriction. We do not sell, trade or otherwise transfer personal data to outside parties, except as described below. We may disclose personal data:
- To our affiliates, including companies and brands within the SmartCirqls group, such as Qila.
- To Data Processors and service providers who help us run our business, such as email, cloud and domain providers (for example Microsoft 365 and Cloudflare), telecom operators and aggregators involved in delivering our short-code services, and our professional advisers.
- To third parties approved by you.
- To our insurers, auditors and banks.
- To parties in a business transaction, such as a buyer or other successor in the event of a merger, demerger, restructuring, or sale of some or all of our assets. The recipient will be bound by confidentiality obligations, and we will anonymise information where we can.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request, or where we believe disclosure is necessary to protect the rights, property or safety of us, our customers or others.
- To enforce our rights arising from any contracts entered into between you and us.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect it, and we impose contractual obligations on them to use it only to provide services to us and to you.
8. Where your personal data is held
Our website runs on our own servers in Mumbai, India. Personal data may also be held at our offices and those of our group companies, service providers and agents described above. Some of these, such as email and cloud providers, may store data outside India. Any transfer outside India will be made in accordance with the DPDP Act and will not be made to a country or territory that the Government of India has restricted.
9. How long your personal data will be kept
We will keep your personal data while we are providing products or services to you, or while we are discussing them with you. After that, we will keep it only for as long as necessary to respond to any questions, complaints or claims; to show that we treated you fairly; or to keep records required by law. We will erase your personal data once the purpose for which it was collected is no longer being served, unless the law requires us to retain it. Where our web servers keep logs, they are kept only for a limited period for security purposes and then deleted.
10. Your rights under the DPDP Act
As a Data Principal, you have the right to:
- Access information about the personal data we process about you, the processing activities, and the identities of other Data Fiduciaries and Data Processors with whom it has been shared;
- Correct, complete, update or erase your personal data;
- Withdraw your consent at any time, where we rely on consent. This does not affect processing that took place before you withdrew it;
- Grievance redressal through our Grievance Officer (section 13), who will respond within the period required by law;
- Nominate another individual to exercise your rights in the event of your death or incapacity; and
- Complain to the Data Protection Board of India if you are not satisfied with our response.
If the GDPR applies to you
If you are in the European Union, the European Economic Area or the United Kingdom, and the General Data Protection Regulation applies to our processing of your personal data, you also have the rights of access, rectification, erasure, restriction of processing, data portability and objection, and the right not to be subject to a decision based solely on automated processing. You may lodge a complaint with the supervisory authority where you live, work or where an alleged infringement occurred.
11. How to exercise your rights
To exercise any of your rights, email us at info@smartcirqls.com. Please give us enough information to identify you (for example your full name, the email address or phone number you used with us, and your company), and a description of the right you want to exercise and the personal data your request relates to. We may ask for further information to verify your identity. Any personal data we collect for verification will be used solely for that purpose.
12. Keeping your personal data secure
We have reasonable security safeguards in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way, including encrypted (HTTPS) connections to this website and restricted access to our servers. We limit access to your personal data to those who have a genuine business need to access it, and they are subject to a duty of confidentiality. We have procedures to deal with any personal data breach, and will notify you and the Data Protection Board of India where we are legally required to do so.
Unfortunately, the transmission of information over the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of personal data transmitted to us, and any transmission is at your own risk.
13. Grievance Officer
If you have a question, concern or complaint about how we handle your personal data, please contact our Grievance Officer:
Grievance Officer, SmartCirqls Infotech Private Limited
1206, 12th floor, Marathon NextGen Icon
Off G.K. Marg, Lower Parel (W)
Mumbai 400013, India
Email: info@smartcirqls.com
14. Children
This website and our services are intended for businesses and adults. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us and we will delete it.
15. Changes to this privacy policy
We may change this privacy policy from time to time. When we do, we will update the date at the top of this page and, where appropriate, tell you by other means such as email.
16. How to contact us
Please contact us by email at info@smartcirqls.com if you have any questions about this privacy policy or the information we hold about you. If you would like this policy in another format (for example audio, large print or braille), please let us know.