Telephone: +1 (408) 834 8842
We collect and process the following data, which may include your personal data.
SMARTe Inc’s Website: If you contact us about our services or request a demo on our website, the forms you complete or the emails you send may include information about you, such as your full name, your email address, the organisation on behalf of whom you are contacting us and your enquiry.
SMARTe Inc’s Online Client Platform: In order to provide a SMARTe Inc Client with access to our platform and enable them to access our services, we collect the full name, email address and password of each individual authorised by such client to access the platform.
The following data may be collected:
SMARTe Inc Database: SMARTe Inc gathers current and historic business contact data. The data collected about individuals on the SMARTe Inc Database comprises:
We also hold data in respect of your employer company such as its name, alias, size, industry, website and industry. In some case we estimate individuals’ net worth based on publically available data (for example, the individual’s employment history or if such individual previously sold shares in a company). Where you have moved jobs, we may hold your previous employers and previous titles.
In order to provide certain aspects of its services, SMARTe Inc requires a business email address to be recorded against profiles in its database. Where SMARTe Inc does not have the business email address of a profile, it may generate a business email address based on the email address structure understood to be implemented by the employer company.
We also hold hashed personal email addresses. Hashing is a method of encryption, whereby the email address itself is confuscated, and replaced with a unique reference instead, called a hash. A hash is one of the means used to locate the same individual on social networking. We do not reverse the hash or use the personal email address to contact you.
The majority of the personal data we collect about you comes from publicly available sources such as from business and employment-oriented social networks, recruitment websites and company websites.
Information is also gathered from correspondence with you (by email or phone), from our clients, recruiters and other premium data providers. SMARTe Inc does not seek to collect any non-business-related data such as date of birth, home address, personal email or telephone number and SMARTe Inc does not collect sensitive personal data.
On some occasions, SMARTe Inc processes your data with your consent. Your consent may be obtained by third parties on SMARTe Inc’s behalf. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn.
3.2 Legitimate interest
SMARTe Inc processes your personal data when it is in our or our clients’ legitimate interest to do so and when these interests are not overridden by your rights. Our and our clients’ legitimate interests include: having information about potential business customers organised in one searchable database, having access to up-to-date and complete information, being able to identify the individual that occupies a certain role within a B2B lead; being able to identify individuals with a certain estimated net worth, enabling clients to only reach out to relevant contacts, being able to generate and contact potential B2B leads in order to undertake forms of B2B marketing, having access to aggregated statistical insights for the purpose of understanding patterns and trends.
3.3 Necessary because of a legal obligation
SMARTe Inc may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
3.4 Necessary to fulfil an obligation under a contract
SMARTe Inc may process your data where we have a contract with the individual and we need to process their personal data to comply with our obligations under the contract.
We will share your information with the following:
4.1 Our companies
Access to personal data within SMARTe Inc and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
4.2 SMARTe Inc clients
We may share personal data with our clients or their customers as part of the offering of our services. SMARTe Inc provides limited access of its database. SMARTe Inc clients or their customers may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail or through targeted display ads on social networks in order to market products and/or services.
4.3 Suppliers, subcontractors, service providers
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
4.4 Data management platform
A Data management platform (DMP) is a technology platform used for collecting and managing data, mainly for digital marketing purposes. SMARTe Inc supplies DMPs with data so that the DMP can generate audience segments, which are used by advertisers to target specific types of users in online advertising campaigns.
4.5 Government authorities
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
4.6 Potential acquirers or investors
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
SMARTe Inc Website and SMARTe Inc Client Platform: We may process your personal data for the following purposes for SMARTe Inc’s own:
SMARTe Inc Database: We may use your personal data on the SMARTe Inc Database for the following purposes:
We also process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
All content: If you send us objectionable content or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behaviour. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
If you do not wish for your personal data to be used in the SMARTe Inc Database for the purposes set out above, please fill in your details here or contact us using the above contact details.
Where you receive a marketing email from us, and you would like to be removed from that mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.
Additional Limits on Use of Your Google User Data:
7.1 App’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements, which is available at the following link: https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes. Please note that these are Google policies, and as such, SMARTe Inc does not have any control or interference on the same. We recommend you to visit Google´s policies directly for further details on their procedures and future updates.
7.2 The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
7.3 The App will not use this Gmail data for serving advertisements.
7.4 The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App’s internal operations and even then only when the data have been aggregated and anonymized.
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please contact us using the above contact details, addressed to the Data Protection Officer.
9.1 You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).
9.2 Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
9.3 Obtain a machine-readable copy of your personal data, which you can use with another service provider
9.4 Make a complaint to a Supervisory Authority
We will hold your personal data for as long as is necessary for the relevant purpose.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@SMARTe Inc.com. We will delete such information from our files within a reasonable time.
SMARTe Inc is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.
Our security measures include:
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Your personal data which you supply to us is generally stored and kept inside the European Economic Area (EEA). However, due to the nature of our global business and the technologies required, your personal data may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.
If you have questions or concerns about our privacy policies and practices, please contact us at the details set out at the top of this Policy.
Please see above for:
We have disclosed and sold personal information to third parties within the last 12 months.
We do not sell the personal information of minors under 16 years of age without affirmative authorization.
You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.
You have the right to:
To make a verifiable request, please contact us using the above contact details, addressed to the Data Protection Officer or call us on 001 8338291090 We may verify your request by asking for proof of identity.
Last updated – 3rd of November, 2021