SmartAlex EU and UK Representative Notice (GDPR Article 27)
1. Purpose and scope
This Notice explains how THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", or "our"), approaches the representative requirement in Article 27 of the EU General Data Protection Regulation and the UK GDPR, in connection with the SmartAlex platform, websites, applications, and APIs (the "Services").
SmartAlex is a company incorporated in the Republic of Singapore. We do not maintain an establishment in the European Union, the European Economic Area, or the United Kingdom. Because our organisation sits outside those territories, specific rules apply where our processing of personal data reaches individuals located within them.
This Notice is an overlay that applies only where the Services are used in a way that brings our processing within the scope of the EU GDPR or the UK GDPR. It does not change the wider commitments described in our broader privacy documentation. It sits alongside, and should be read together with, the documents listed in Section 5.
For the purposes of this Notice:
- EU GDPR means Regulation (EU) 2016/679, the General Data Protection Regulation, as it applies in the European Union and the European Economic Area.
- UK GDPR means the retained version of Regulation (EU) 2016/679 as it forms part of the law of the United Kingdom, read with the Data Protection Act 2018.
- Representative means a natural or legal person established in the European Union or the United Kingdom, designated in writing under Article 27, who acts as a point of contact for supervisory authorities and individuals on matters relating to our processing.
- Article 27 means Article 27 of the EU GDPR and the equivalent provision of the UK GDPR that together set out the representative requirement described in this Notice.
2. When a representative is required
Under Article 27 of the EU GDPR, a controller or processor that is not established in the European Union must, in certain circumstances, designate in writing a Representative located in the European Union. The requirement is triggered where the processing relates to:
- the offering of goods or services to individuals who are in the European Union, whether or not payment is required; or
- the monitoring of the behaviour of individuals as far as their behaviour takes place within the European Union.
The UK GDPR contains an equivalent requirement. A controller or processor that is not established in the United Kingdom must, in comparable circumstances, designate a Representative located in the United Kingdom.
Article 27 provides for a limited exemption. The requirement to designate a Representative does not apply to processing that is occasional, that does not include, on a large scale, processing of special categories of data or of data relating to criminal convictions and offences, and that is unlikely to result in a risk to the rights and freedoms of individuals, taking into account the nature, context, scope, and purposes of the processing. The exemption also does not apply to public authorities or bodies. Whether the exemption is available depends on the specific facts of a given processing activity.
Where a Representative is required, its designation is in addition to, and does not affect, our own responsibilities and liabilities as a controller or processor.
3. SmartAlex's position
We keep our processing activities under review to assess whether, and to what extent, they bring us within the scope of the EU GDPR or the UK GDPR and trigger the Article 27 requirement.
Where our processing triggers the Article 27 requirement and no exemption applies, we will designate a Representative in the relevant territory in writing, and we will publish the Representative's identity and contact details in this Notice. Where a Representative has been designated, its details will appear in a clearly labelled block in this Section.
3.1 EU and UK Representative details
Where an EU or UK Representative has been appointed, the Representative's name and contact details are set out below.
At the effective date of this version, no Representative has yet been appointed. Once a Representative is designated, its name, address, and contact details will be published in this Section and this Notice will be updated accordingly. Until then, individuals and supervisory authorities should contact us directly using the details in Section 4 and Section 6.
4. Contacting SmartAlex directly
Individuals located in the European Union or the United Kingdom may contact us directly about our processing of their personal data, the exercise of their rights, or any related concern, at privacy@getsmartalex.com. Supervisory authorities may use the contact details in Section 6.
Where a Representative is designated, it serves as an additional point of contact and does not replace the ability to contact us directly. Individuals may choose to raise a matter with the Representative, with us, or with both. Reaching out to a Representative is never a precondition to contacting us.
5. Relationship to other documents
This Notice works together with the other legal documents that govern the Services. In particular, it should be read alongside:
- the GDPR Article 13 Notice, which sets out the information we provide when we collect personal data;
- the UK GDPR and PECR Notice, which addresses United Kingdom data protection and electronic communications rules;
- the Privacy Policy, which describes our overall approach to personal data; and
- the Data Processing Addendum, which governs our processing of personal data on behalf of customers who act as controllers.
If there is any inconsistency between this Notice and those documents on the specific subject of the Article 27 representative requirement, this Notice governs that subject. On all other subjects, the relevant document governs.
6. Updates and contact
We may update this Notice from time to time to reflect changes in our processing activities, in the designation of a Representative, or in applicable law. When a Representative is appointed or changed, we will update Section 3 and the version and effective date below. We encourage individuals and supervisory authorities to review this Notice for the current position.
Questions about this Notice, or about our processing of personal data, may be sent to privacy@getsmartalex.com. Legal correspondence may be sent to legal@getsmartalex.com.
This Notice is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.
7. Version and effective date
This EU and UK Representative Notice is version 1.0 and is effective from 8 July 2026.