Effective Date: 04-11-2020
#1. Your Data
We collect two basic types of information from You from Your use of the Website: Personal Data and Non-Personal Data.
#2. Personal Data
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
As a general matter, You can browse the Website without submitting Your Personal Data to Us. However, there are a number of circumstances in which You may supply Us with Your Personal Data.
#2.1 Data We Collect
We collect the following Personal Data from You:
- Phone Number;
#2.2 How We Collect Data
The following are the most common ways in which You give Your Personal Data:
- Participating in communities, chat rooms and comment threads, other fora, and other interactive services in the Website;
- Submission of User Content on any part of the Website that permit it;
- Any other place in the Website where You knowingly volunteer to give Personal Data.
#3. Personal Data On Or From Social Media
When You interact with the Website or Your Account through a social media platform, such as Facebook, Twitter, Tumblr, LinkedIn, YouTube, or Pinterest, We may collect the Personal Data that You make available to Us on that page including Your account ID or handle. We will comply with the privacy policies of the corresponding social media platform and We will only collect and store such Personal Data that We are permitted to collect by these social media platforms.
Please do NOT supply any other person's Personal Data to Us, unless We prompt You to do so.
#4. Use of Personal Data
We do NOT sell or license Your Personal Data to any third party.
In addition to the specific purposes for which We may process Your Personal Data set out in this clause, We may also process any of Your Personal Data where such processing is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
Specifically, We use Your Personal Data for the following:
- responding to Your queries and requests;
- investigating complaints;
- enforcing Our Terms and Conditions;
- as otherwise required or authorized by law or government agency.
- customizing Services;
- rewards, competitions, marketing or other promotional materials;
- recognizing You when Your return to Our website;
- creating personalized offers;
#5. Sharing Of Personal Data
We may share your Personal Data with the following:
- Social networking sites
- Analytics services
- IT service providers and web hosting companies
- Legal, auditing and other professional advisors or consultants
- Billing or data storage services
Other Purposes. In addition to the specific disclosures of Personal Data set out in this Section, We may disclose Your Personal Data where such disclosure is necessary for compliance with a legal obligation to which We are subject, or in order to protect Our vital interests, Your vital interests, or the vital interests of another natural person. We may also disclose Your Personal Data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
#6. Retaining and Deleting Personal Data
Personal Data that We process for any purpose shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain Your Personal Data for a maximum period of 6 months.
In some cases, it is not possible for Us to specify in advance the periods for which Your Personal Data will be retained. In such cases, We will determine the period of retention based on our legitimate interests, namely the proper administration of Our Website and business.
Notwithstanding the other provisions of this Section, We may retain Your Personal Data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
#7. Data Security
We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in Our possession. This includes, for example, firewalls, password protection and other access and authentication controls.
We use HTTPS
HTTPS (Hypertext Transfer Protocol Secure) is an internet communication protocol that protects the integrity and confidentiality of data between your computer and www.smatoos.io/. The use of HTTPS makes sure your communication with us is:
Encrypted — The data you exchange with us is secure from eavesdroppers. That means that when you are browsing www.smatoos.io/, nobody can track your activities across multiple pages, or steal the data exchange between your computer and www.smatoos.io/.
Integral — The use of HTTPS preserves the integrity of data. Your data cannot be modified or corrupted during transfer.
Authenticated — HTTPS protocol authenticates your communication with us. This ensures that you are always communicating with our servers.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information You transmit to Us or store on the Website, and You do so at Your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards. If You believe Your Personal Data has been compromised, please contact Us at firstname.lastname@example.org.
If We learn of a security systems breach, then We attempt to notify You electronically so that You can take appropriate protective steps. We may post a notice through the Website if a security breach occurs.
#8. Non-Personal Data
Non-Personal Data includes information that does not personally identify You, but may include tracking and usage information about Your location, demographics, use of the Website and the internet.
When You interact with the Website, We may collect Non-Personal Data and Our servers may automatically keep an activity log of Your use of the Website.
#8.1 Generally, We collect and store the following Non-Personal Data:
- Demographic information such as age, gender, and five-digit zip code as part of collecting Personal Data;
- Device information about Your computer, mobile device, or other device that You use to access the Website. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information;
- Usage information about Your use of the Website. This information includes a reading history of the pages You view.
- Additional “traffic information” such as time of access, date of access, software crash reports, application errors, session identification number, access times, and referring site addresses.
- Your search terms and search results.
- Other information regarding Your use of the Website.
#9. Use of Non-Personal Data
We may disclose or share Non-Personal Data (or other information, other than Personal Data) in any other manner that We deem appropriate or necessary.
Among other things, We will disclose Non-Personal Data to third parties to help Us determine how users use parts of the Website and who Our users are so We can improve the Website.
We will also disclose Non-Personal Data to Our partners and other third parties about how Our users collectively use the Website.
#10. Personal & Non-Personal Data From Other Sources
We may also collect and store information about You that We receive from other sources to, among other things, enable Us to update and correct the information contained in Our database and to better customize Your experience on the Website.
#11. Source IP Address/Location Data
We collect and store Your device’s source IP address which may disclose the location of Your device at the time You access the Website. Advertisements and certain content may be directed to You as a result of this information.
In some cases, the Website can deliver content based on Your current location if You choose to enable that feature. If You enable that feature, Your current location will be stored locally on Your device which will be used by the Website to serve You certain content tied to Your location. If You elect to have Your location-based searches saved to Your history, We will store such information on Our servers.
#12. Account Data
We may process Your Account Data ("Account Data"). The Account Data may include Your name and email address. The source of the Account Data is You. The Account Data may be processed for the purposes of operating Our Website, providing Our Services, ensuring the security of Our Website and Services, maintaining back-ups of Our databases and communicating with You. The legal basis for this processing is our legitimate interests, namely the proper administration of Our Website and business.
#13. User Content Data
We may process information that You post for publication on Our Website or through Our Services ("User Content Data"). The User Content Data may be processed for the purposes of enabling such publication and administering Our Website and Services. The legal basis for this processing is consent.
#14. Customer Relationship Data
We may process information relating to Our customer relationships, including customer contact information ("Customer Relationship Data"). The Customer Relationship Data may include Your name, Your contact details, and information contained in communications between You and Us. You are the source of the Customer Relationship Data. The Customer Relationship Data may be processed for the purposes of managing Our relationships with customers, communicating with customers, keeping records of those communications and promoting Our Goods and Services to customers. The legal basis for this processing is Our legitimate interests, namely the proper management of Our customer relationships.
#15. Transactions And Payment Data
We may process information relating to transactions, including purchases of Goods and Services, that You enter into with Us and/or through Our Website (“Transaction Data”). The Transaction Data may include Your contact details, Your card details, the transaction details, and/or your authentication details. The Transaction Data may be processed for the purpose of supplying the purchased Goods and Services and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the proper administration of Our Website and business and a contract between user and you or taking steps at user request to enter a contract.
#16. Notifications Data
We may process information that You provide to Us for the purpose of subscribing to Our email notifications and/or newsletters ("Notification Data"). The Notification Data may be processed for the purposes of sending You the relevant notifications and/or newsletters. The legal basis for this processing is consent.
#17. Correspondence Data
We may process information contained in or relating to any communication that You send to Us ("Correspondence Data"). The Correspondence Data may include the communication content and metadata associated with the communication. Our Website will generate the metadata associated with communications made using the Website contact forms. The Correspondence Data may be processed for the purposes of communicating with You and record-keeping. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our Website and business and communications with users.
#18. Your Data Privacy Rights
If You are a citizen of the EU, We have summarized the rights that You have under the General Data Protection Regulation (GDPR) in this Section. Some of the rights are complex, and not all of the details have been included in Our summaries. Accordingly, You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Right to Access.
You have the right to confirmation as to whether or not We process Your Personal Data and, where We do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. Providing the rights and freedoms of others are not affected, We will supply to You a copy of Your Personal Data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
Right to Rectification.
You have the right to have any inaccurate Personal Data about You rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about You completed.
Right to Erasure.
In some circumstances You have the right to the erasure of Your Personal Data without undue delay. Those circumstances include: the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the Personal Data have been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
Right to Restrict Processing.
In some circumstances You have the right to restrict the processing of Your Personal Data. Those circumstances are: You contest the accuracy of the Personal Data; processing is unlawful but You oppose erasure; We no longer need the Personal Data for the purposes of Our processing, but You require Personal Data for the establishment, exercise or defense of legal claims; and You have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, We may continue to store Your Personal Data. However, We will only otherwise process it: with Your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
Right to Object to Processing.
You have the right to object to Our processing of Your Personal Data on grounds relating to Your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in Us; or the purposes of the legitimate interests pursued by Us or by a third party. If You make such an objection, We will cease to process the Personal Data unless We can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to Our processing of Your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If You make such an objection, We will cease to process Your Personal Data for this purpose.
You have the right to object to Our processing of Your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to Your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Right to Data Portability.
To the extent that the legal basis for Our processing of Your Personal Data is consent, or that the processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means, You have the right to receive Your Personal Data from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
Right to Complain to a Supervisory Authority.
If You consider that Our processing of Your Personal Data infringes data protection laws, You have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of Your habitual residence, Your place of work or the place of the alleged infringement.
Right to Withdraw Consent.
To the extent that the legal basis for Our processing of Your Personal Data is consent, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of Your rights in relation to Your Personal Data through written notice to Us. See Our Contact Details at the end of this Policy.
#19. Data Protection
If You are located in the European Economic Area, Your Personal Data will be processed by SMATOOS HONGKONG. As part of providing the Website, this Personal Data may be transferred to other regions, including to Canada and the United States. Such transfers will be completed in compliance with relevant Data Protection Legislation.
When SMATOOS HONGKONG processes Personal Data in the course of providing the Website, SMATOOS HONGKONG will:
- process the Personal Data as a Data Processor, only for the purpose of providing the Website in accordance with documented instructions from You (provided that such instructions are commensurate with the functionalities of the Website), and as may subsequently be agreed to by You. If SMATOOS HONGKONG is required by law to Process the Personal Data for any other purpose, SMATOOS HONGKONG will provide You with prior notice of this requirement, unless SMATOOS HONGKONG is prohibited by law from providing such notice;
- notify You if, in SMATOOS HONGKONG’s opinion, Your instruction for the processing of Personal Data infringes applicable Data Protection Legislation;
- notify You promptly, to the extent permitted by law, upon receiving an inquiry or complaint from You or a Supervisory Authority relating to SMATOOS HONGKONG’s Processing of the Personal Data;
- implement and maintain appropriate technical and organizational measures to protect the Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorized or unlawful processing, accidental loss, destruction, damage or theft of Personal Data and appropriate to the nature of the Personal Data which is to be protected;
- notify You promptly upon becoming aware of and confirming any accidental, unauthorized, or unlawful processing of, disclosure of, or access to the Personal Data;
- ensure that its personnel who access the Personal Data are subject to confidentiality obligations that restrict their ability to disclose the Personal Data; and
- upon termination of the Terms, SMATOOS HONGKONG will promptly initiate its purge process to delete or anonymize the Personal Data. If You request a copy of such Personal Data within 60 days of termination, SMATOOS HONGKONG will provide You with a copy of such Personal Data.
#20. International Transfer Of The Personal Data of EU Citizens
In this Section, We provide information about the circumstances in which Personal Data of citizens of the European Union may be transferred to countries outside the European Economic Area (EEA).
We have offices and facilities in Hong Kong.The European Commission has made an "adequacy decision" with respect to the data protection laws of Hong Kong. Transfers to Hong Kong will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. A copy of the use of standard protection clauses adopted or approved by the European Commission can be obtained through: ec.europa.eu
The hosting facilities for Our Website are situated in Korea, Republic Of. The European Commission has made an "adequacy decision" with respect to the data protection laws of Korea, Republic Of. Transfers to Korea, Republic Of will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. A copy of the use of standard protection clauses adopted or approved by the European Commission can be obtained through: ec.europa.eu
You acknowledge that Personal Data that You submit for publication through Our Website or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
The legal basis for this processing is Our legitimate interests, namely the proper administration of Our Website and business and communications with users.
#21. Data Protection Officer
Our data protection officer's contact details are: email@example.com.
#22. Your Choices
In general, if You register on the Website, You may update the information You have provided to Us.
When You register on the Website, You may be able to indicate Your preferences regarding marketing communications. You may be able to change those preferences and select the categories of communications that interest You.
You will not be able to opt-out of receiving certain service-related or transactional communications relating to the Website unless You cancel Your registration or subscription.
#23. Your Right to Access
We provide You with reasonable access to the Personal Data that You may provide through the Website.
#24. Your Right to Withdraw Consent
At any time, You may legitimately object to the processing of Your Personal Data, except if otherwise provided by applicable law. You may decline to share certain Personal Data with Us, in which case We may not be able to provide to You some of the features and functionality of the Website.
#25. Your Right to Update, Correct or Delete
You may update, correct, or delete Your Account Data and preferences at any time by accessing Your Account settings page on the Website. If You wish to access or amend any other Personal Data We hold about You, or to request that We delete any information about You that We have obtained from an Integrated Service, You may contact Us. Please note that while any changes You make will be reflected in active user databases instantly or within a reasonable period of time, We may retain all information You submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where We otherwise reasonably believe that We have a legitimate reason to do so.
We will however retain Your information needed for administrative and transactional communications.
#26. California Privacy Rights
If You are a California resident, California Civil Code Section 1798.83 permits You to request and obtain from We, information regarding the disclosure of Your Personal Data to the third parties for direct marketing purposes in the preceding calendar year, free of charge, once a year.
California residents, who are under 18 and are registered users of We, are allowed to request and have removed, any content or information that they have posted publicly. However, in cases where the law does not require or allow the removal of information, this may not be applicable. This is under California Business and Professions Code Section 22581.
California Do Not Track Disclosure: We do not track the personally identifying information of Our users and visitors over time and across third party websites to provide targeted advertising. We respond to Do Not Track (DNT) signals. However, some other third-party websites do keep track of Your browsing activities so that they can tailor the information or advertising they present to You. If You wish to opt out of this tracking, You can enable privacy settings in Your browser.
#27. No Personal Data From Children
We do not knowingly collect Personal Data from children under 13 years of age in the USA or 16 years of age in the European Union. The Website is not directed to children under the age of 13 in the USA or 16 in the European Union. We will not knowingly allow children under 13 in the USA or 16 in the European Union to register for or become users of the Website.
If You are under 13 in the USA or 16 in the European Union years of age, You should not provide Personal Data to Us.
If We discover that a child under the age of 13 in the USA or 16 in the European Union has provided Us with Personal Data and We do not have parental consent, We will immediately delete that child’s information.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but Personal Data that We store about You may be linked to the information stored in and obtained from cookies.
#28.1 Cookie We Use
These are temporary cookies that contain no expiration date and are deleted after the users browser is closed. You will be required to log in again at the next session, where you will be treated as a new user
Session cookies examples: Shopping cart, remembering previous actions, managing and passing security tokens, multimedia content player session cookies, load balancing session cookies and third party social content plug in sharing cookies
These are cookies which are saved in your browser until they are deleted by the you or are deleted by your browser after they reach their expiration date.
Persistent cookies examples: Authentication, language selection, theme selection, favorites, internal site bookmarks, menu preferences, address and payment information.
Functionality cookies allow us to remember choices that have been made by you in order to create an experience that’s made to fit. These cookies safely store authentication and identification information, for example your language selection or region.
Performance cookies allow us to collect information, such as the most used pages or error messages, in order to understand how you use our website and enable us to create a better user experience. All information collected by performance cookies in anonymous.
#28.2 Purpose Of Using Cookies
#28.3 Cookies Used by Our Service Providers
#28.4 Managing Cookies
You can disable cookie tracking and learn more about the privacy policies of the third parties We use by visiting the following links:
#29. Links To Or From Another Website
#30. Public Areas
Please remember that any information You share in public areas, such as message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what You disclose and do not post any Personal Data that You expect to keep private. Please consult the applicable guidelines, if any, for use of Our chat rooms and other community areas for more information.
#31. Interest Based Advertising
To help ensure that You receive ads that are relevant to Your interests on the Website, Our advertisers’ services, and elsewhere on the Internet, We and third parties (including service providers, advertisers, and advertising companies) may collect information about Your online activities over time and across different sites, apps, and devices. We and third parties may use that information to help understand audience segments. Advertisers may use the segments to determine the audience groups to which they wish to deliver particular ads. Through this process, We do not use information that directly identifies You.
Opt Out. You can opt out of receiving interest-based advertising on Your computer or laptop from some companies, including Us and Our service providers.
If You wish to opt out of receiving interest-based advertising on Your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com for Android devices.
Opting out does not mean You will no longer receive advertising. It means that the company or companies from which You opted out will no longer deliver ads tailored to Your web preferences and usage patterns.
#32. Changes And Updates
#34. Our Details
If you have questions or concerns regarding this policy or if you need to make a request please contact us at:
- Contact Data Controller: firstname.lastname@example.org
- Contact Data Protection Officer: email@example.com