The Company respects the confidentiality of Users of its products and services, as well as the provisions of current laws on the protection of privacy, including the laws of the European Union.
Any capitalized terms used in this Policy, to the extent not specifically defined in this Policy, shall have the meaning as provided in the User Agreement.
1. TERMS FOR ACCESS TO THE SITE
By providing services through the Site and its services, the Company, acting reasonably and in good faith, presumes that the User:
i. has all necessary rights permitting him/her to register and use this Site and related services;
ii. provide accurate information about himself/herself to the extent necessary to use the Site.
2. PURPOSES OF PERSONAL DATA PROCESSING
The Company processes information about Users, including their Personal Data, in order to fulfill the Company's obligations to Users regarding the use of the Site.
For the purposes of the Site use Personal Data shall mean any information related directly or indirectly to a specific or identifiable individual (Personal Data subject), and processing shall mean any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.
3. TYPES OF PERSONAL DATA COLLECTED AND PURPOSE OF USE
3.1. TECHNICAL DATA
The Company automatically collects the following Personal Information when you use the Site:
i. Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform;
ii. Information about your visit to websites, including the full URL of unified resource pointers (URLs) on, through, and from websites (including the date and time);
Products you viewed or searched for;
page response time, loading errors, the length of time you visit or use certain pages, page interaction information (such as scrolling, clicking, and hovering), and methods used to navigate from the page.
This information is necessary to improve the operation of the Site, fulfill our administrative purposes and protect our business interests.
3.2. REGISTRATION DATA
In order to use the Site in terms of services developed by the Company, in particular access to the Smart Portfolio, you need to go through the Registration procedure. When going to the Registration section, you will be offered to enter your Registration data: e-mail and password. You will also be asked to enter your first and last name and phone number as part of the Registration and completion of the forms.
After completing the registration, you can optionally specify your country of residence, date of birth, and upload images of your account.
The purpose of processing such data is to identify the User. The entered e-mail/password pair is necessary and sufficient information for the User's access to the Site. The User is not allowed to transfer its login and password to third parties, is fully responsible for their safety, choosing the method of storage by itself. The User can allow the storage of login and password (using cookies) for further automatic authorization on the Site on the hardware and software used by the User.
4. PRINCIPLES OF PROCESSING
Processing of personal data is based on the following principles:
a. the lawfulness of the purposes and methods of processing personal data;
b. good faith;
c. compliance of the purposes of personal data processing with the purposes predetermined and stated when collecting personal data, as well as with the scope of the Company's authority;
d. compliance of the scope and nature of processed personal data, methods of processing personal data to the purposes of processing of personal data;
e. the prohibition of combining databases created for incompatible purposes, containing personal data.
5. DATA STORAGE
When collecting Personal Data of Users and Visitors, the Company provides recording, systematization, accumulation, storage, clarification (updating, modification), extraction of your Personal Data using databases located in the European Union.
The Personal Data that the Company processes would not be stored for longer than is required for the relevant purposes. The Company will store your Personal Data for the duration of your contractual relationship with the Company and, to the extent permitted, after the termination of this relationship for as long as it takes to fulfill the purposes set out in this Policy.
The storage period for the required data can be extended for tax compliance purposes. In particular, information about the purchase of Products, Subscriptions, and access may be stored by the Company for 5 years or until the tax audit is completed, depending on what happens later. Other Personal Data will be deleted 12 months after the deletion of the Personal Account is approved.
We will stop processing your data if you object to such processing of your data or if you have withdrawn your consent to processing that was previously received by the Company.
6. RIGHTS OF PERSONAL DATA SUBJECTS
Subjects of Personal Data processed by the Company have all rights and opportunities to exercise them in accordance with the provisions of the applicable law. In particular, the Company provides the following User’s rights:
The right to be informed: under your request and at the moment of collecting we will provide you information about the collection and use of your Personal Data, in particular, about purposes for processing these data, retention periods for that personal data, and who it will be shared with. If we obtain Personal Data from other sources, we will inform you about this within a reasonable period upon obtaining the data and no later than one month, unless you already have the information or if it would involve a disproportionate effort to provide it to you.
Right of access: you have the right to receive confirmation as to whether or not your Personal Data are being processed, and, if there is a need, access to the Personal Data. If the Personal Data are transferred in the third country, you have the right to be informed about your rights relating to such transfer.
Right to rectification: you have the right to have inaccurate personal data rectified or completed if it is incomplete under request for rectification made verbally or in writing.
Right to restriction of processing: you have the right to request the restriction or suppression of your Personal Data. Where processing has been restricted, such Personal Data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.
In some jurisdictions whose laws apply to the processing of certain Users' data, such Users may be granted other additional rights.
7. CONFIDENTIALITY AND SECURITY OF PERSONAL DATA
We take the privacy and security of your Personal Data very seriously. We have implemented technical and organizational security measures to ensure that data protection from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and any other unlawful or unauthorized forms of processing is an integral part of all Personal Data processing in accordance with applicable law.
We do not disclose this information to third parties except with your consent, in accordance with the provisions of this Policy, or if we believe that such disclosure is necessary (for a legitimate purpose: for example, if you or other persons are threatened) under applicable law.
The Site may contain links to websites maintained by third parties whose information and privacy practices differ from ours (for example, when processing payments). We are not responsible nor liable for the information or privacy practices used by such third parties. We recommend you read the privacy policies of all third-party websites before using such websites or providing any Personal Data or any other information on or through such websites.
8. CHANGING THE POLICY
This Policy may be revised, changed, updated and / or supplemented at any time, without the need for prior notification to the User, at the Company's discretion. If we make such changes, we will post a notification on the main page of the Site. The date of this Policy update will be displayed on the first page of the Policy. We strongly recommend Users to check the page regularly for changes. Each User agrees that it is his/her own responsibility to review from time to time the current version of the Policy.
By using the Site, the User automatically confirms their consent to this Policy in the applicable part. If the User does not agree with this Policy, we strongly recommend you stop using the Site.
After posting the updated version of the Policy on the Site, further use of the Site is considered as acceptance of the terms of the updated Policy.
If you have any questions, please send them to Support team at the following e-mail address: firstname.lastname@example.org.
Last updated: March 10, 2021