Introduction
We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with your access to and use of the Website.
In this Privacy Notice, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual. This Privacy Notice explains which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.
Definitions
Unless otherwise provided in this Privacy Notice, capitalised terms used in this Privacy Notice have the meaning determined in the Smarty Pay Legal Disclaimer (the “Legal Disclaimer”). We encourage you to read this Legal Disclaimer carefully as it affects your legal rights.
Identity and Contact Details
When we say “Smarty Pay”, “we”, “us”, or “our”, we mean Smarty Network Ltd., a company established under the laws of Seychelles that acts as the operator of the Website. With respect to personal data collected in connection with your access and use of the Website, we act as a data controller, meaning that we solely determine what data collected as well as the purposes and means of processing of your data.
We process your personal data in accordance with this Privacy Notice and we endeavour to comply with the applicable data protection legislation.
If you have any questions regarding this Privacy Notice or the processing of your personal data, do not hesitate to contact us at business@smartypay.io.
Type of Data
We collect and process the following types of personal data as outlined below.
Data Use
Storage Period
As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:
a) to meet our legal obligations under the applicable law;
b) in relation to anticipated or pending legal proceedings; or
c) to protect our rights and legitimate interests or those of third parties.
Data Sharing
General. We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, applicable data protection legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary:
a) to enable you to access and use the Website; or
b) for compliance with the applicable laws and regulations.
Please note that if we share any portion of your personal data with third persons, we will endeavour to secure such transfer using appropriate legal, organisational, and technical measures.
Recipients. Given the purposes outlined above, your personal information may be shared with the following categories of recipients:
a) affiliates;
b) analytical solution providers, such as Google, LinkedIn, HubSpot, Wix, Cloudflare;
c) support and technical teams;
d) online chat providers;
e) marketing teams;
f) hosting service providers;
g) government authorities, upon their request or if necessary to comply with our legal obligations;
h) another entity if we sell or otherwise transfer the Website; and
i) other third-party solutions, which may be from time to time integrated into the Website.
No Automated Decision-Making
Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. We do not make any automated decisions based on your personal data. If we intend to process your personal data by any automated means, we will do our best to inform you about the same prior to such processing.
Third-Party Links
The Website may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share certain data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy/notice/statement of every website or application you visit.
Rights
According to the applicable data protection legislation, you may have the rights outlined below. In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.
Data of Children
The Website is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children.
If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.
Modifications
We keep our Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice to check for the updates. If we make substantial changes to the way we treat your personal information, we will display a notice on the Website.
Cookies
General. Cookies are, in effect, small data files that are placed on the browser of a visitor’s device (such as computer, smartphone, tablet, etc.) when accessing online content and by which it is possible to recognise that device when it interacts with or returns to the Website (the “Cookies”). Cookies and similar technologies use unique codes that act as an identifier and, in certain circumstances, may be treated as personal data under the applicable data protection legislation. This is because they can enable the user of a device to be uniquely recognised as the same user, even if their “real world” identity is unknown. Please note that we may involve third-party service providers to collect and process certain Cookies.
Consent. When you first access the Website, you have the right to decide whether to accept or reject non-essential and non-functional Cookies. You do not need to allow non-essential and non-functional Cookies to access and use the Website. However, enabling non-essential and non-functional Cookies may allow us to analyse the Website use, better understand your needs and create a more tailored browsing experience. You may disable Cookies within the Cookies preference centre available within the Website, if any, or by changing your browser settings at any time. How you can do this will depend on the browser you use. Most browsers (for example, Microsoft and Google) have dedicated privacy pages that explain how websites collect, handle, and pass on information to third parties.
Cookies Types. Essential and functional Cookies are required for the Website to operate properly. We do not need your consent to operate such Cookies since these Cookies ensure basic functionalities and security features of the Website, anonymously. We are required to get your consent to operate the non-essential Cookies, such as those used to analyse your behaviour on the Website, target you with relevant advertisements, etc., e.g., analytical, functional, targeting cookies. Cookies allow us to know how many users visited the Website, how long they stayed on the Website, what sections they visited, etc. This helps us to provide a better experience and to understand the content you find useful.
Third-Party Service Providers. The Cookies are generally provided by third-party solutions, such as Google, HubSpot, Wix, Cloudflare and LinkedIn. More information regarding such third-party solutions is provided below. With respect to personal data collected via third-party solutions, they act as our data processors. However, if they use this personal data for any of their own purposes, such as profiling and cross-platform tracking, they act as independent data controllers.
