Privacy policy

GENERAL INFORMATION

This privacy policy regulates how SmartApe OÜ processes personal data and describes your rights as a "data subject".

CONTACT INFORMATION

Controller (operator) of data is SmartApe OÜ, Registry code 16124388, Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151, Estonia.

VAT ID No. EE102329731

Any questions related to data processing can be sent to privacy@smartape.net.

SmartApe strives to process such incoming emails as quickly as possible, but not for longer than one month.

AREA OF VALIDITY

The given Policy applies to all online services of SmartApe OÜ:

• The Billing System at https://cp.smartape.net with secured client area;
• SmartApe OÜ websites and their subdomains;
• Control panels of SmartApe OÜ online services;
• Requests to technical support.

If you refuse to accept this Policy, please do not use SmartApe OÜ online services.

This Privacy policy does not apply to third party services, platforms, social media, or services that can be available through SmartApe OÜ online services or integrated with them. For instance, during the payment process you can be redirected to a specific payment service website. You can leave comments on Websites through the integrated comments service. In such cases, data processing will be out of SmartApe OÜ control. Such third party services are independent controllers acting upon their own privacy policies.

Certain rules clarifying statements of this Policy can be included in other regulations, agreements, and rules, which define terms and conditions of SmartApe OÜ online services. Please read these documents carefully and agree with them to continue.

HOW DO WE PROCESS PERSONAL DATA?

SmartApe OÜ stores and uses your personal data only for processing your orders, communicating with you and improving our services.

When processing personal data, SmartApe OÜ is guided by the following principles:

• Personal data is processed on a lawful and reasonable basis;
• It is allowed to process only those personal data that are consistent with the purposes of data collection;
• The processing of personal data is limited to specific predefined legal purposes. The content and volume of data processed must not be excessive. Data processing incompatible with the purposes of data collection is not permitted;
• Databases with personal data that will be processed for incompatible purposes with each other are not consolidated;
• During the processing of personal data, this data must be accurate, sufficient and current in relation to the purposes of collecting personal data. Inaccurate or insufficient data should be removed or revised where necessary;
• Data must be protected from unauthorized or illegal processing, unintentional loss, damage and destruction.
• Personal data is stored no longer than is required by the purposes of collecting personal data;

SmartApe OÜ uses personal data for the following purposes:

1. Compliance with legal requirements, such as tax laws.
2. Fulfillment of mutual obligations of SmartApe OÜ and the user on the basis of agreements and conditions for the provision of the SmartApe OÜ online services.
3. Electronic mailings and other communication channels. SmartApe OÜ can send various types of messages, including email, SMS and messages in the account area. System messages are necessary for SmartApe OÜ to timely fulfill its obligations to users. Such messages are used to ensure the proper performance of SmartApe OÜ online services. These can be messages about the status of the service, payments, password change and other similar questions. Marketing and promotional messages are sent only if the user has explicitly agreed to receive such messages. You can always configure the parameters for receiving such messages in your personal account.
4. Protection against copyright infringement, fraud or other unfair behavior.
5. Improvement, support and modernization of SmartApe OÜ online services. These processes are essential for error prevention and remediation, security, technical problem resolution, and usage analysis and monitoring.
6. Interaction with the user, for example, responding to inquiries and contacting the user directly to discuss setting up, using and renting SmartApe OÜ online services. To do this, we use the data provided by the user when ordering the SmartApe OÜ online services, as well as data from open sources.
7. Organization of research using anonymous data.
8. Establishment and control of payments, maintenance of accounts and their administration.

If the data is processed for the purposes specified in clauses above, with the exception of marketing and advertising messages, SmartApe OÜ proceeds from the existence of a corresponding legitimate interest.

WHAT CATEGORIES OF INFORMATION DO WE COLLECT?

Every time you visit our website, client area and control panels of our online services we process your personal and other information (including anonymous information) that is not directly considered personal data. These could be device specifications, error logs, connection data, or how you interact with an interface.

SmartApe OÜ does not process certain types of data, for example: information about political or religious beliefs, past convictions, biometric data, health status or other similar information.

SmartApe OÜ does not intentionally process any personal data of persons under the age of 16.

If you believe that SmartApe OÜ could have received personal data from a person who has not reached the age that allows him to give independent consent to the processing of data, please inform us about such a case using one of the methods listed in the "CONTACT INFORMATION" section.

In particular, we store the following data about you:

Personal data

When you register an account on our website or our billing system, send request to our support, use account area or our control panels you provide us your personal data. This data may include last name, first name, email address, address, billing information and telephone number. Other personal information may be requested depending on the scope of the obligation. SmartApe OÜ uses this data to fulfill its obligations, conduct transactions, fulfill tax obligations and defend against complaints and claims. SmartApe OÜ does not collect or store information about your bank cards.

Some personal data may be provided to SmartApe OÜ by third parties. In most cases, you have the right to grant, deny, or restrict third party disclosures. For example, you can log in to websites through social networks. In this case, you authorize social networks to provide SmartApe OÜ with your email address or other information. We cannot receive any information on our own, unless you have allowed it in your social media settings.

Usage Data

SmartApe OÜ collects information about how you use our online services in order to make them better. Such information may include device type, operating system version, error logs, and quantity usage parameters.

Cookie files

SmartApe OÜ uses cookies and other identical technologies to collect information. More information can be found in the Cookie Policy.

Log Files

Our servers automatically store technical information about access to them. This happens when you open our websites, use the account area in our billing system and control panels, or our other online services. The log data may contain information about IP address, browser characteristics, date, time, duration of actions and their sequence. After that, you will not be able to be identified. The legal basis for this data processing is Art. 6 (1) lit. f GDPR.

HOW DO WE STORE DATA?

SmartApe OÜ stores data for a period of time necessary to achieve the goals of data collection.

Regardless of the user's request to delete information, SmartApe OÜ has the right to store information if this is required to protect legitimate business interests, fulfill its obligations and resolve disputes.

After achieving the goals of data processing, there is no need to achieve such goals, or in case of receiving the relevant requirements, these data should be deleted or anonymized. SmartApe OÜ has the right to store data, despite the request to delete it, if this data is required for specific legal interests of the business, to ensure the fulfillment of obligations or to resolve disputes.

TO WHOM DO WE DISCLOSE INFORMATION?

SmartApe OÜ discloses information to third parties only if it is regulated by this policy or applicable law, to the extent necessary to achieve the goals of information disclosure.

Disclosure of information is allowed in the following cases:

• if a special notification has been received from the user. Such a notification can be the addition of a new trusted entity to the Account area by the User and granting him access to the relevant information;
• comply with the requirements of the current legislation. The data can only be disclosed after receiving a request from the competent authority;
• for providers of additional services referred to by SmartApe OÜ. These can be services for monitoring website activity, sending email, licensors or subcontractors. Such suppliers should use personal data only in accordance with SmartApe OÜ recommendations for the purposes specified in this policy. For more information on the limits of disclosure and who may be disclosed, see the OUR BUSINESS PARTNERS section;
• to protect rights, prevent illegal activities, guarantee the security of SmartApe OÜ and other parties, as well as protect against disputes and claims;
• if general, aggregated or anonymized data are used. SmartApe OÜ has the right to disclose anonymized statistical data, for example: about the most frequently used functions of our online services;
• transfer information during the reorganization of SmartApe OÜ, as well as during the execution of user agreements. In such cases, SmartApe OÜ reserves the right to disclose the information to a third party that acquires rights in accordance with the contract, or to a party that will be created as a result of such reorganization;
• for affiliates of SmartApe OÜ in order to fulfill obligations to the user. Such affiliates are described in the OUR BUSINESS PARTNERS section;
• in other cases when the user's consent has been obtained.

HOW DO WE PROVIDE DATA SECURITY?

SmartApe OÜ uses reliable technical and organizational measures to protect data. SmartApe OÜ can:

• establish local documents describing the processing of personal data. These documents regulate the procedures to avoid or identify violations and eliminate the consequences of such violations;
• organize a periodic review of the conditions governing the processing of personal data;
• appoint a person responsible for organizing the processing of personal data;
• organize a periodic review of the conditions governing the processing of personal data;
• familiarize employees directly involved in the processing of personal data with the provisions of laws governing personal data, including special requirements for the protection of personal data, documents or any other internal documents related to the processing of personal data;
• apply any legal, organizational and technical measures to ensure the security of personal data during their processing.

SmartApe OÜ cannot guarantee that information will be completely protected from intrusions during its transmission over the Internet or storage. SmartApe OÜ uses pseudonymisation and data encryption where conditions permit.

TO WHOM WE TRANSFER YOUR DATA

External service providers may have access to your data while they assist us in providing our services. In some cases, third parties such as government agencies, our business partners or external consultants may obtain your data. Such third parties must provide decent data protection at least as set out in this Policy.

POLICY CHANGES

SmartApe OÜ has the right to amend this Policy in accordance with changes in legislation or business processes. All such changes will be published on the SmartApe OÜ website. If such revision directly or indirectly affects the rights of the user, SmartApe OÜ will send users notifications by e-mail and / or in the account area.

YOUR RIGHTS AS A DATA SUBJECT

User rights must be respected in accordance with Applicable Law and recognized international law.

You have the right to:

• receive information about the processing of personal data. SmartApe OÜ maintains its current policy in an actual state, thereby providing you with correct information about the collected data, the purposes of its collection and other aspects of processing;
• withdraw your consent to the processing of personal data, if such processing is based on consent. For example. You can always unsubscribe from advertising or marketing emails in your account;
• object to data processing. The user may object to the processing of personal data for direct marketing purposes;
• access information, its updates, changes and specifications. In most cases, you can manage the status of your information in your account;
• request deletion of data. SmartApe OÜ reserves the right to continue processing data after receiving a request, if this is permitted by applicable law;
• request the export or import of data, if technically possible. You can obtain such a right upon request in your account. Data is exported to CSV;
• request for limitation of processing. This right can only be exercised in special cases, for example: to challenge the accuracy of the data during the data clarification period or to determine improper processing. If such a request to restrict data processing has been received, SmartApe OÜ is not entitled to process any data without the additional consent of the user. However, the processing of data necessary to protect against complaints and claims can be carried out even without such consent of the user.

Other rights may be provided by applicable law.

OUR BUSINESS PARTNERS

SmartApe OÜ may engage subcontractors and service providers to fulfill its obligations to users and to establish its reasonable legitimate interests.

These business partners receive a strictly limited set of data required to perform their functions. SmartApe OÜ takes all possible measures to guarantee the confidentiality of data transmission until the business partner is involved. This section presents such business partners, their location and functions.

COOKIE POLICY

This section defines how, when and why SmartApe OÜ uses cookies and similar technologies.

By using SmartApe OÜ online services, you automatically agree to use cookies and identical technologies in accordance with this document and the Privacy Policy. If you do not wish to use these technologies, please use the settings described in the HOW TO DISABLE COOKIE section.

WHAT ARE COOKIES?

Cookies are small text files that are stored on your computer or mobile device when you use websites and your account area. Each cookie is unique for each account or web browser.

WHAT COOKIE WE USE

SmartApe OÜ uses cookies and identical technologies such as pixel and web beacon. Typically, this is a 1 pixel gif file that you can open to obtain information such as the technical parameters of your connection.

SmartApe OÜ uses session and persistent cookies. Session cookies are created during the period of time that your web browser is open and are automatically deleted after you close your browser. Persistent cookies are created until they are deleted by themselves or until the time specified in the cookies expires.

In addition, SmartApe OÜ uses cookies that are set by third parties, for example: analytical systems such as Google Analytics.

Some cookies are associated with your account and provide authorization. Other cookies are not associated with your account; however, because they can be unique, they can retain settings, interface elements, your preferences, and previous selections.

Cookies allow you to use all the functions of the websites and account area.

In addition, cookies differ in the way they are used. SmartApe OÜ uses several of these cookies.

HOW TO DISABLE COOKIES

Most modern web browsers allow you to manage your security settings. The user can restrict the storage and use of cookies and add certain websites to exceptions.

The settings for each web browser are described in its documentation.

Use the following links to find settings for the most popular web browsers.

• Google Chrome (Desktop)
• Google Chrome (Android)
• Google Chrome (iOS)
• Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

You can restrict the use of cookies from third parties, such as Google Analytics, on the Google website. In addition, you can restrict the use of pixels or web beacons on social networks in the security settings of those social networks.

If you restrict the use of cookies, SmartApe OÜ's online services may malfunction. For example, the system may not be able to save settings, ensure successful authorization, send messages, or guarantee the correct operation of our services.

SmartApe OÜ is not responsible for the inability to use SmartApe OÜ online services due to the restrictions imposed on the use of cookie technology.