Last updated 08th April 2022
Important information and who we are This privacy notice aims to give you information on how SmartExpert Inc. collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller SmartExpert Inc. is the controller and responsible for your personal data (collectively referred to as “SmartExpert”, “we”, “us” or “our” in this privacy notice). Where we process your personal data in order to provide our service, we are the data processor and the person who issued a request/invitation to you to access our platform (for example, your employer) is the data controller. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details Full name of legal entity: SmartExpert Inc. Email address: [email protected] – Postal address: 919 North Market Street, Suite 950 in the City of Wilmington, County of New Castle, Zip Code 19801
Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
Automated technologies or interactions.
Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:Technical Data from the following parties: analytics providers such as Google; advertising networks; and search information providers. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from data brokers or aggregators.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
How we store and secure information we collect Information storage.
We use data hosting service providers in the USA to host the information we collect, and we use technical measures to secure your data.
Technical and organizational security procedures and data transfers.
We observe reasonable procedures to prevent unauthorized access to and the misuse of Personal Data. We use appropriate business systems and procedures to protect and safeguard Personal Data. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorized personnel are permitted to access Personal Data in the course of their work. For more information on where we store your information and our security measures, please contact us as provided in the Contact Us section below. If you are a customer or partner that specifically requires the implementation of model contractual clauses directly with SmartExpert, where appropriate and where SmartExpert is a data processor for the customer or partner, please contact us as provided in the Contact Us section below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
OPT-OUT PREFERENCES: If you no longer want to receive marketing-related emails from us, you may opt out of receiving such emails by clicking the “unsubscribe” link at the bottom of any marketing email you receive from us. If you are having difficulty unsubscribing from our marketing emails using the above methods, please contact us directly at the email [email protected].
How long we keep information (retention procedures)
SmartExpert will store your personal information for as long as necessary to perform the purposes of processing as stated in this Policy. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. SmartExpert stores the email addresses of the users who receive the results of test or dialogue simulations for six (6) months in order to restore the results and send them to You or Your users. SmartExpert no longer uses this data: after a month retention period, all the data will be deleted.
United States - California residents
To exercise your rights under the CCPA, please submit a written request to office@smartexpert., please indicate which right your request is for and provide a description to help us understand the nature of your request. Your authorized agent may submit requests in the same manner. In order to fulfil any rights requests, SmartExpert is required to verify your identity, so please be aware that SmartExpert may need to request additional information that will be used for that purpose.