Privacy Policy

Privacy Policy 
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.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. 

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. 

The security of your personal information is important to us. We follow generally accepted security standards and we have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information. For more information on where we store and how we secure your information, please see our compliance and security page. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach. If you have any reason to believe that your interactions with the Services are no longer secure, please notify us immediately at [email protected]. We may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal information.If you have any questions about the security of your personal information, you can contact us at [email protected]Your rights: You can access and update your information in your site account at any time; You can deactivate your site account if you no longer wish to use our Services; You can request the information SmartExpert has collected about you; You can request that we make changes to the Personal Data you have seen, but cannot change in your site account; You also have the right to obtain from us the erasure of your Personal Data (right to be forgotten); In addition, you may, under certain circumstances, have the right to restriction of the processing of your Personal Data; You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data; You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when the processing is based on your consent or is necessary for the performance of a contract (the right to data portability); You can opt-out of promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your site account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt-out of receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt-out of some notification messages in your site account settings; You can refuse the use of cookies: relevant browser-based cookie controls are described in our Cookie Policy. SmartExpert acknowledges that EU individuals have the right to access the personal information that we maintain about them. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe. 

United States - California residents 
This section provides additional details about the personal information SmartExpert collects about California customers, as well as the rights of California consumers under the California Consumer Privacy Act (CCPA). How SmartExpert Collects, Uses, and Discloses your Personal Data. The section “What information SmartExpert ring may collect about you in our role as data controller” describes in detail the Personal Data SmartExpert may have collected over the last 12 months, including identification information, internet activity information. SmartExpert have collected such Personal Data directly from you and from your interaction with the site and the Services.SmartExpert collects this information for the purposes described in the “What information SmartExpert may collect about you in our role as data controller” and “Why SmartExpert processes your personal information in our role as data controller" sections. SmartExpert shares this information with the categories of third parties described in the “How we share your personal information in our role as data controller” and “Information we receive from third-party integrations” sections. SmartExpert uses cookies, as described in SmartExpert Cookie Policy SmartExpert does not sell (as defined by the CCPA) your Personal Data. Your CCPA Rights and Choices. As a California customer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information: Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months: the categories and specific pieces of personal information we have collected about you; the categories of sources from which we collected the personal information; the business or commercial purpose for which we collected the personal information; the categories of third parties with whom we shared the personal information; and the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose. Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law. Opt out of sales. California's residents have the right to instruct businesses that sell their personal information to stop doing so. SmartExpert, however, does not sell your personal information. Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights. 

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. 

CHANGES TO THIS PRIVACY POLICY: We reserve the right to amend all or part of our Privacy Statements from time to time. The version published on the Sites is the version currently in force. Changes to our Privacy Statements are communicated by placing a notice on the Sites stating “Revised Privacy Statement(s).” Changes to our Privacy Statements will be effective immediately once published on the Sites unless otherwise noted. Your use of the Sites following any amendments indicates your consent to the practices described in the revised PrivacyStatements. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We invite you to periodically review our Privacy Statements to be informed of any relevant changes, especially before providing any data to us. CONTACT US: SmartExpert Inc. 919 North Market Street, Suite 950 in the City of Wilmington, County of New Castle, Zip Code 19801 [email protected]