This Privacy Policy explains how SmartGreg PTE. LTD. collects, uses, discloses, and protects your personal data when you use the Krovan mobile application, including when you buy products through the App. Please read it carefully. By downloading, installing, or using Krovan, you agree to the practices described below.
1.Who we are
Krovan (the "App") is owned and operated by SmartGreg PTE. LTD. ("SmartGreg", "we", "us", or "our"), a company incorporated in Singapore. For the purposes of applicable data protection law, including the Singapore Personal Data Protection Act 2012 (the "PDPA"), SmartGreg PTE. LTD. is the data controller responsible for your personal data.
Our representative in Cambodia. Neary Skin Co. LTD is our appointed representative in the Kingdom of Cambodia. Cambodian users may contact Neary Skin Co. LTD locally with any question or request relating to this policy or their personal data, and we will handle it together. Neary Skin Co. LTD is also the seller of record for products offered through the App in Cambodia: it sells and fulfils those orders, and it processes order, delivery, and payment information for that purpose. Its contact details are in Section 15.
Krovan is a lifestyle application that provides a personal habit tracker, a library of lifestyle articles, and an online shop through which you can browse and buy products. Our users are located primarily in Cambodia, and we are committed to handling their personal data responsibly and transparently.
2.Scope of this policy
This policy applies to personal data we collect through the Krovan mobile application and any related services we provide, including the online shop and order fulfilment carried out by Neary Skin Co. LTD. It does not apply to third-party products, websites, or services that we do not own or control, even where they are linked from within the App (see Section 13). Payments made through third-party payment providers are also subject to those providers' own privacy policies (see Section 4).
3.Information we collect
We aim to collect as little personal data as possible. The information we collect falls into the categories below.
3.1 Information you provide to us
When you create an account or use certain features, we ask you to provide:
- Your name — used to identify and personalise your account.
- Your phone number — used as your account identifier, to verify that you are a real user, and to contact you about your orders.
- Your date of birth — asked once, to confirm that you meet the minimum age for Krovan (see Section 12).
When you place an order, we also collect the information described in Section 4.
3.2 Phone number verification
To confirm that your phone number belongs to you, we send a one-time verification code by SMS or Telegram. To deliver this code, your phone number is shared with the messaging or SMS delivery provider that transmits the message. This is used solely to complete verification and to secure your account; we do not use it for marketing.
3.3 Information collected automatically
To keep the App reliable and to understand how it is used, we and our service providers automatically collect certain technical information when you use Krovan. This may include:
- App usage data, such as which screens, products, and features are opened and general interaction patterns;
- Device and technical data, such as device model, operating system version, app version, language settings, and approximate region;
- Diagnostic and crash data, such as error logs and the state of the App at the time of a crash.
We use Google Analytics for usage analytics and Sentry for crash and error reporting. These tools help us measure engagement and fix problems. Where possible, this information is used in an aggregated or de-identified form.
4.Orders, payments & delivery
When you buy a product through the App, we and Neary Skin Co. LTD collect and process the information needed to complete that purchase.
4.1 Order and delivery information
- Delivery address — the recipient name, street address, commune/district/province or city, and any delivery notes or landmarks you provide.
- Contact details for delivery — the phone number to be used by the courier, which may be your account phone number or another number you give us.
- Order details — the products ordered, quantities, prices, discounts or promotion codes, order date and status, delivery status, and your order history.
- Communications about your order — messages, support requests, returns, complaints, and refund or cancellation requests relating to a purchase.
4.2 Payments
Payments are processed by third-party payment providers, currently ABA PayWay and Wing / Bakong (KHQR). When you pay, you are directed to the provider's own secure flow and you provide your payment details directly to that provider. We and Neary Skin Co. LTD do not receive or store your card number, CVV, PIN, or banking credentials.
Our payment providers give us back only what we need to confirm and reconcile the transaction — for example, a transaction reference, the amount and currency, the payment method used, the time of payment, and whether the payment succeeded, failed, or was refunded. Payment providers process your data as independent controllers under their own privacy policies and under the banking and anti-money-laundering rules that apply to them; we encourage you to read those policies.
4.3 Delivery
To get your order to you, the delivery address and the delivery contact phone number are shared with the courier or delivery partner handling the shipment, and only for that shipment. Delivery partners may confirm delivery status back to us and to Neary Skin Co. LTD.
5.How we use your information
| Purpose | Data used |
|---|---|
| Create and manage your account | Name, phone number |
| Verify your identity and secure your account | Phone number, verification code |
| Provide the habit tracker and lifestyle articles | Name, usage data |
| Process, fulfil, and deliver your orders | Name, phone number, delivery address, order details |
| Take and confirm payment, and process refunds | Order details, transaction reference and status from the payment provider |
| Keep you informed about your order and provide customer support | Name, phone number, order and communication data |
| Handle returns, complaints, and disputes | Order, payment, delivery, and communication data |
| Maintain, troubleshoot, and improve the App | Usage, device, and crash data |
| Confirm that you meet the minimum age | Date of birth |
| Understand how features and products are used and prioritise improvements | Aggregated usage and order data |
| Measure our advertising and reach people similar to our customers — only with your permission (see Section 7) | Hashed name, phone number, date of birth and country; a pseudonymous account identifier; the fact that you created an account; order value and product identifiers |
| Protect against fraud, abuse, and security threats | Phone number, device and diagnostic data, order and transaction data |
| Meet accounting, tax, and other legal obligations | Order and transaction records, as required by applicable law |
We do not use your data for automated decision-making that produces legal or similarly significant effects, and we do not send marketing messages unless you have separately agreed to receive them.
6.Consent & legal basis
We collect and use your personal data on the basis of your consent, which you provide when you register and use the App, and where such collection and use is reasonable and appropriate under the PDPA and other applicable laws.
- We rely on your consent to process your name and phone number.
- Where you place an order, we process your delivery, order, and transaction data because it is necessary to perform the purchase contract between you and Neary Skin Co. LTD — without it, an order cannot be accepted, delivered, or paid for.
- We rely on our legitimate interest in keeping the App secure, functional, and improving to process technical, usage, and crash data, and to prevent fraud and abuse.
- We retain certain transaction records to comply with legal obligations, including accounting and tax requirements.
- We share data with our advertising and measurement partner (Section 7) only on your separate, explicit consent, which you give on a dedicated screen in the App and can withdraw at any time in Settings › Privacy. Nothing is shared before you allow it, and refusing changes nothing else about the App.
You may withdraw your consent at any time (see Section 11). Please note that some data is essential to operate the App or to complete an order — if you withdraw consent for it, we may no longer be able to provide you with an account, certain features, or purchases.
7.How we share information
We do not sell or rent your personal data. We share it only in the limited circumstances below, and only to the extent necessary:
- Neary Skin Co. LTD (Cambodia). As our local representative and the seller of record in Cambodia, Neary Skin Co. LTD receives the order, delivery, contact, and payment-confirmation data needed to sell, fulfil, deliver, and support your purchase, and to meet its own legal, accounting, and tax obligations.
- Payment providers. ABA PayWay and Wing / Bakong (KHQR) receive the information needed to process your payment. You provide your payment credentials directly to them; they act as independent controllers under their own privacy policies.
- Delivery partners. Couriers and logistics providers receive the recipient name, delivery address, and delivery phone number needed to deliver your order.
- Service providers. We use trusted third parties to operate the App on our behalf, including Google Cloud Platform (hosting), our SMS and Telegram message delivery providers (verification codes), Google Analytics (usage analytics), and Sentry (crash reporting). These providers may only process your data on our instructions and for the purposes described in this policy.
- Advertising and measurement partner (Meta). Only if you allow it in the App, we share limited data with Meta Platforms, Inc. (Facebook and Instagram) so that Meta can measure which of our advertisements led to installs, sign-ups, and purchases, and show Krovan to people similar to our customers. What we share: your name, phone number, date of birth, and country as SHA-256 hashes (never in plain text), a pseudonymous identifier for your account, the fact that you created an account, and purchase events consisting of the order value and product identifiers — never your delivery address, and never anything about your payment. On iPhone, iOS additionally asks for tracking permission; nothing is shared unless you allow both. Meta processes this data as an independent controller under its own Privacy Policy and Business Tools Terms, and discards the hashed contact data once matching is complete. You can stop the sharing at any time in Settings › Privacy in the App (on iPhone also in iOS Settings › Privacy & Security › Tracking, on Android in Settings › Google › Ads); sharing stops from that moment on, though data already shared remains subject to Meta's policy. Independently of your choice, the Meta software kit inside the App reports app installs and launches to Meta so that we can count installs from our advertising; those reports carry none of the personal data above.
- Legal and safety reasons. We may disclose information where required by law, court order, or a valid request from a competent authority, or where necessary to protect the rights, safety, or property of our users, the public, SmartGreg, or Neary Skin Co. LTD.
- Business transfers. If SmartGreg is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction, subject to the protections in this policy.
8.Where your data is stored
Krovan's infrastructure is hosted on Google Cloud Platform in the Singapore region. Because SmartGreg is based in Singapore and some of our service providers and partners (such as Google Analytics, Sentry and, if you allow the sharing described in Section 7, Meta in the United States) operate globally, your personal data may be processed or stored in Singapore and other countries.
Order, delivery, and payment-related data is also processed in Cambodia by Neary Skin Co. LTD, by our payment providers, and by delivery partners, so that your purchase can be fulfilled locally.
When personal data is transferred outside your country of residence, we take steps to ensure it receives a standard of protection comparable to that required under the Singapore PDPA, including through contractual safeguards with our providers and with Neary Skin Co. LTD.
9.Data retention
We keep your personal data only for as long as necessary to provide the App and for the purposes set out in this policy, or as required by law.
- Your name and phone number are retained for as long as your account is active.
- Order, delivery, and transaction records are retained for as long as needed to complete the order, handle returns, warranty claims, refunds, and disputes, and thereafter for the period required by applicable accounting, tax, and commercial law in Cambodia and Singapore — even if you delete your account.
- Your choice about advertising data sharing is kept with your account for as long as the account exists, so that we can honour it.
- Aggregated or de-identified data that can no longer be linked to you may be retained for analytics.
If you delete your account or ask us to delete your data, we will remove or anonymise your personal data within a reasonable period, unless we are required to retain it to meet legal, accounting, security, or fraud-prevention obligations.
10.Security
We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration. These include hosting on secured Google Cloud infrastructure, encryption of data in transit, access controls, phone-number verification to reduce unauthorised account access, and limiting access to order and delivery data to the staff of SmartGreg and Neary Skin Co. LTD who need it to fulfil your order. Payment credentials are handled entirely within our payment providers' regulated systems and are never stored by us.
No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping access to your device and account secure, and for not sharing verification codes or payment credentials with anyone.
11.Your rights
Subject to applicable law, including the Singapore PDPA, you have the right to:
- Access the personal data we hold about you;
- Correct personal data that is inaccurate or incomplete;
- Withdraw consent to our collection, use, or disclosure of your personal data;
- Delete your account and request deletion of your personal data;
- Ask questions about how your personal data is handled.
To exercise any of these rights, contact us at privacy@smartgreg.com, or contact our Cambodian representative, Neary Skin Co. LTD (see Section 15). We may need to verify your identity before acting on your request, and we will respond within a reasonable time in accordance with applicable law. Please note that we may be unable to delete order and transaction records that we are legally required to keep (see Section 9).
12.Children's privacy
Krovan is intended for people aged 16 and over. We ask for your date of birth once to confirm this, and an account below the minimum age cannot use the App. Krovan is not directed at children under the age of 13, and we do not knowingly collect personal data from them. Purchases through the App may only be made by users who have the legal capacity to enter into a contract. If you believe a child has provided us with personal data without appropriate consent, please contact us and we will take steps to delete it. Where required by local law, minors should use the App only with the consent and supervision of a parent or legal guardian.
13.Articles, products & links
Krovan provides lifestyle articles for general information only. These articles are not professional medical, health, financial, or legal advice, and should not be relied upon as such. Product descriptions, ingredient lists, and usage guidance shown in the shop are provided for information and are not a substitute for professional advice; if you have a medical condition or a known allergy, consult a qualified professional before using a product.
Sales of products through the App are governed by our Terms of Sale, which cover pricing, delivery, returns, and refunds. The App may contain links to third-party websites or resources, including payment provider pages. We are not responsible for the privacy practices or content of those third parties, and we encourage you to review their privacy policies before providing them with any personal data.
14.Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the "Last updated" date above and, where appropriate, notify you within the App. Your continued use of Krovan after an update means you accept the revised policy.
15.Contact us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection contact:
Attn: Data Protection / Privacy
Registered in Singapore
Email: privacy@smartgreg.com