Information we collect through the Website
How We Collect User Information
We act on assumption that consumers prefer relevant ads, tailored in accordance with their interests. Therefore, we collect a variety of data using cookies and various other standards (typical for the industry) and unique (if our technology allows so) web technologies to collect information automatically from Your device, including:
Tags and Pixels. Tags and Pixels are blocks of code that we and our clients may use to track Your browsing on the Internet: from resources to any particular websites or applications to track Your browsing behavior. Sometimes web beacons are used for these purposes. They are usually transparent or invisible graphic images, no larger than 1x1 pixel, they are placed on a page or otherwise, Internet resource or sent within an e-mail to monitor the behavior of the user visiting the resource or sending the e-mail. It is often used in combination with cookies. We create and use a unique synchronization system to check the quality of information that we have collected with information that our clients collected independently, and later help our clients or third parties that intend to provide You with targeted advertisements.
Mobile Device Identifiers. Mobile Device Identifiers or Mobile Device IDs are unique identifiers which can be used to identify a mobile device. We may use standard device identifiers, to track Your use of mobile applications and to determine if a piece of advertisement inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing device’s ID back to advertisers helps us and our clients to improve the quality of advertising and its efficiency.
Other technologies. Please be aware that we use other technologies, including locally stored objects, to collect user information in order to assist users with the inventory delivery and to provide reporting to our clients or to evaluate the quality of advertisement.
Information You may provide to SMARTHUB
When You are filling out forms via the Website, We may ask You to provide information (a) by which You may be personally identified, such as name, company name, business email address, or any other personal or personally identifiable information under applicable law (hereinafter the “Personal information“), and/or (b) that is about You but individually does not identify You. Also, You may fill in the “Message” field in the contact form and provide Us with the plain text containing additional information that may include a portion of personal data.
This information includes:
A) Information that You provide by filling in forms on the Website. This includes information provided at the time of registering to use or access the Website. We may also ask You for information when You interact with Us (such as when responding to notices and announcements from Us) or otherwise correspond with Us.
B) Records and copies of Your correspondence (including email addresses), if You contact Us;
C) Your responses to surveys that We might ask You to complete for research purposes.
How we use the information we collect
We use the data collected through the Website for a variety of purposes including:
- to better understand how people use the Website
- to provide and maintain our Service
- To provide customer support
- to prevent fraud, and to improve the effectiveness, security and integrity of the Website
We use the data provided by You by filling in forms on the Website in order to contact You and for the purposes of signing the WLS Service agreement.
We may use the data to protect and enforce our agreements and property rights, to comply with court orders, legal processes or respond to regulatory or other similar requests.
We share the information with
- Our subsidiaries and affiliates: vendors and agents performing or providing goods and services on our behalf (for example data storage providers and information storage providers)
- Other third parties but only in aggregate form or as may be required by law
Data storage and retention
Data we collect through the Website may be processed and stored in the United States, or in other countries where we or our service providers or data storage providers process data. We take steps to ensure that data is processed according to this Policy and to the requirements of applicable law of Your country and of the additional countries where the data is subsequently processed.
We keep any information we collect through the Website as long as we need it for business, tax, or legal purposes. After that, we destroy it.
Security of Your data
We’ve established electronic and administrative safeguards designed to make the information We collect from the Website secure. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge You to always use caution when transmitting information over the Internet.
Links to other websites
SUBSECTION FOR EEA USERS ONLY
Your Rights and Applicability of the EU Laws
Our Data Protection Officer can be reached via e-mail: email@example.com
or by post using the details provided below:
DEOX SOFT CORP dba SmartHub
Attn: Privacy Officer
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
- We need to perform a contract with You
- You have given us permission to do so
- The processing is in our legitimate interest, and it's not overridden by Your rights
- To comply with the law
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If You are a resident of the European Economic Area (EEA), You have certain data protection rights. SMARTHUB aims to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.
If You wish to be informed what Personal Data we hold about You and if You want it to be removed from our systems, please contact us at firstname.lastname@example.org
In certain circumstances, You have the following data protection rights:
- The right to access, update or to delete the information we have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact us to assist You;
- The right of rectification. You have the right to have Your information rectified if that information is inaccurate or incomplete;
- The right to object. You have the right to object to our processing of Your Personal Data;
- The right of restriction. You have the right to request that we restrict the processing of Your personal information;
- The right to data portability. You have the right to be provided with a copy of the information we have on You in a structured, machine-readable and commonly used format;
- The right to withdraw consent. You also have the right to withdraw Your consent at any time where SMARTHUB relied on Your consent to process Your personal information;
- You have the right to lodge a complaint with a supervisory authority
Please note that we may ask You to verify Your identity before responding to such requests
For more information, please contact Your local data protection authority in the European Economic Area (EEA)
END OF THE EEA USERS SUBSECTION
The Residents Of The State of California Rights
According to the California Consumer Privacy Act (“CCPA”) then amended by The California Privacy Rights Act (CPRA) the California residents have the following rights listed in this clause:
- You have theright to know and see what information we have collected about You over the past 12 months, including: the categories of information we have collected about You; the categories of sources from which the information is collected; the business or commercial purpose for collecting Your information; the categories of third parties with whom we have shared Your information; and the specific pieces of information we have collected about You;
- You have theright to request that We delete or correct the information We have collected from You (and direct our service providers to do the same);
- You have theright to “opt-out” or direct us to stop “selling” or otherwise sharing Your information with third parties in exchange for money or other valuable consideration
To submit an opt-out request, please contact us at email@example.com/or submit the required verifying information, by contacting us here.
UK Data Subject Rights
After Brexit, the UK is no longer regulated domestically by the EU's General Data Protection Regulation (GDPR), which governs processing of personal data from individuals inside the EU. Instead, the UK now has its own version known as the UK-GDPR (United Kingdom General Data Protection Regulation). The new UK-GDPR took effect on January 31, 2020.
Under the UK-GDPR, individuals can exercise: the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; the right to object to processing; the rights in relation to automated decision making and profiling
If You would like to exercise any of these rights (as a resident of UK) , please contact us with a reasonable proof that You are subject to these rights.
Please note, as we already stated most information we deal with is anonymized when we receive and process it, therefore, we cannot identify You individually, You need to provide us with some additional information to enable us to identify the user information You are referring to, it may be technologically impossible to identify Your information, although we will try to accurately fulfill Your request. Please also read regarding our responsibility for the actions of our clients in Section I.
Data Protection Rights of The Residents of Brazil
SMARTHUB comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD.
We hereby inform You about the following rights You have under the LGPD:
- Confirmation: confirmation of the existence of processing;
- Access: access to the data;
- Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD;
- Data portability: portability of the data to other service providers or suppliers of product, at the express request;
- Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD;
- Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent;
- Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent;
- Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD;
- Bring complaint: lodging a complaint with the Data Protection Authority;
- Opposing the processingof personal data where there is non-compliance with the provisions of LGPD;
- Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality
If You would like to exercise any of these rights, please contact us via: firstname.lastname@example.org
Data Protection Rights of The Residents of China
SMARTHUB comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”). The beforementioned principles includes among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.
We hereby inform You about the rights You have under the PIPL:
- You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;
- You have the right to access and copy Your personal information in a timely manner, except when the laws and regulations require confidentiality;
- You have the right to correct or complete inaccurate personal information in a timely manner;
- You have the right to request Us to explain Our personal information handling rules;
- You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;
- You have the right to request Us to transfer Your personal information to another personal information handler
If You would like to exercise any of these rights, please contact us via: email@example.com
Data Protection Rights of The Residents of Virginia and Colorado
SMARTHUB expresses its willingness to comply with any and all the principles and requirements of data processing under Colorado’s Consumer Data Protection Act (CPA) that will be effective on July 1, 2023, and under Virginia Consumer Data Protection Act (VCDPA) effective January 1st, 2023.
If You have any questions in regard to Your rights under the aforementioned legislation, please don’t hesitate to contact us via: firstname.lastname@example.org
If You have questions about privacy on the SMARTHUB Website, You can send us a message here: email@example.com
You can also contact us by post using the details provided below:
DEOX SOFT CORP dba SmartHub
Attn: Privacy Officer