This document concerns the manner and scope of how we process the personal data of you as a natural person. Please read the following information carefully before providing your personal data to us. If you are a visitor of a website that uses Smartlook, please be aware that the controller of your personal data is the provider of that website. You can find more information in section A of this Privacy Policy.

If you have any questions regarding the processing of your personal data, please contact us at privacy@smartlook.com.

Personal Data Controller:

Smartlook.com, s.r.o.

ID No.: 095 08 830

with its registered office at: Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic, EU

privacy@smartlook.com

Contact details of data protection officer: dpo@smartlook.com

A. If you are visitor of website that uses Smartlook

When you visit a website that uses Smartlook, we will process your information under the direction of the website provider, whose privacy policy will apply to your personal data. Similarly, you have to contact the website provider if you want to exercise your rights with respect to your personal data.

We only process your data to provide our services to the website provider, our customer. To make sure your data are adequately protected, we enter into Data Processing Agreements with our customers.

If you don't want to be recorded by Smartlook, you can opt-out here. Please note that if you clear your cookies or use a different browser, you will need to opt-out again.

B. Personal data processed by us as data controller

We will process the following personal data you provide to us while setting up your user account, when requesting a demo or when using Smartlook.com via the Smartlook.com access interface:

  • name and surname

  • address

  • job title

  • name of organization

  • phone number

  • email address

  • invoicing details (name of entity, tax identification number)

  • IP address

  • activity and movement at website www.smartlook.com

Purpose and legal basis of the processing of your personal data

We will process your personal data for the following purposes and based on the following legal bases:

  1. Processing for the purpose of contract performance and fulfilment of legal obligations

We need to process the following personal data:

  • name and surname

  • address

  • job title

  • phone number

  • email address

  • invoicing details (name of entity, tax identification number)

We need to process these personal data concerning you in order to fulfil the Smartlook.com service contract you are entering into with us.

Our company provides you with its services, or, more specifically, the Smartlook.com service, in accordance with the terms and conditions accessible at https://www.smartlook.com/help/terms-of-service/. In order for us to provide you with the Smartlook.com service, we need to know who the other party is and, if you use paid features, we also need to know your payment information.

Please note that under the contract you may receive emails with technical and operational notices regarding the Smartlook.com service functionality. These notices are part of our communication with you as a party to the contract. The purpose and legal basis of the processing of your personal data in this case therefore involves performance of the Smartlook.com service contract. Such emails do not constitute “direct marketing” as it is mentioned in point 2 below, and you may not opt-out of them.

The legal basis for processing in this case is Art. 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”).

We also need to process this kind of personal data to fulfill our other legal duties. Under several laws (e.g. tax and accounting laws), we have to process personal data stipulated above. The legal basis in this case is Art. 6(1)(c) of General Data Protection Regulation.

2. Processing for the purposes of direct marketing

We process the following personal data:

  • name and surname

  • email address

  • geolocation based on your IP address

  • name of organization

for the purpose of direct marketing, which constitutes a legitimate interest of our company.

This data processing will be done in the following manner:

Your personal information will be stored in our electronic database kept with a company that provides us with a data repository, which, however, is managed directly and exclusively by us. Based on our legitimate interest, as specified above, your personal data will only be used through third-party services (for more details see Categories of personal data recipients) to send you product offers, whether these involve new features or existing products and Smartlook.com service extensions.

The legal basis for processing in this case is Art. 6(1)(f) of General Data Protection Regulation.

If you do not wish to receive our product and Smartlook.com service feature offerings, you can simply opt out in the settings of your user account or click the unsubscribe link provided in each email containing our offerings.

3. Processing undertaken to improve our customer support

We process the following personal data:

  • name and surname

  • email address

  • job title

  • name of organization

  • phone number

  • IP address

  • activity and movement at website www.smartlook.com

for the purpose of improving our customer support if you give us your consent through the settings of your user account on Smartook.com.

We will record your IP address and track your activity and behavior at Smartlook.com in order to improve the efficiency of our user support in the event you need any help or advice on using the Smartlook.com services.

We track visitor activity and behavior at Smartlook.com every time you access the site and analyze product adoption and product usage statistics using automated means. The resulting data allow us to provide more effective user support if you need any help or advice using Smartlook.com.

We will use the IP address through which you first accessed Smartlook.com when registering to determine which country you are from, so that we can allocate the most relevant customer support representative. However, we will only detect and store your IP address once when you register at Smartlook.com. We will not detect your IP address at any other time when you access Smartlook.com.

The legal basis for processing in this case is therefore your consent, based on Art. 6(1)(a) of General Data Protection Regulation.

If you change your mind regarding the processing of these personal data, you can easily withdraw your consent at any time (by turning off IP address recording and visitor activity tracking at Smartlook.com) in your user account settings. In the same way, you can re-grant your consent to us after you withdraw it.

We will process your personal data on the basis of the consent you have granted only for the period, during which the consent applies, i.e., from the grant of the consent to its withdrawal. However, we will only process these personal data as long as your user account exists. Furthermore, we delete individual track recordings concerning your activity and your behavior at Smartlook.com after 360 days at all times.

In all cases, we will process your personal data in electronic information systems. However, these systems are subject to consistent and ongoing physical and technical checks. All persons who, on our instruction and under our authority, come into contact with your personal data in the course of their work or as part of their contractual duties are bound by confidentiality obligations.

4. Processing of personal data from the demo-request form

We process the following personal data:

  • name and surname

  • role

  • e-mail

  • phone number

  • name of organization

  • country of origin

  • other information you provide to us

for the purpose of mutual communication and pre-contractual negotiations.

If we agree on further cooperation based on mutual communication, personal data will be processed on the basis of fulfilment of contractual obligations under Art. (6)(1)(b) of General Data Protection Regulation. Otherwise we will only process personal data for the purposes of dealing with your enquiries and requests based on the legitimate interest of ensuring mutual communication under Art. (6)(1)(f) of General Data Protection Regulation.

Personal data are stored in our electronic databases hosted by AWS. We may also share this data with companies providing other services as stated in “Categories of personal data recipients”.

All personal data will be stored only for the duration necessary to meet the purposes stated above. If we enter into a contractual relationship with you, we will process your personal data for the duration of the relationship or longer as described in section 1 above.

You can also opt-in to receive emails containing Smartlook news and updates by checking a box in the demo request form. If checked, we will process your personal data until you withdraw your consent.

Categories of personal data recipients

We will primarily process your personal data on our own. However, we may have to entrust some personal data processing services to a third party for any of the aforementioned purposes. In such a case, the relationship between us and such third party will be that between a controller and a data processor and we will have entered into a personal data processing agreement with that processor to guarantee the security and lawfulness of the processing of your personal data.

Therefore, your personal information may be transmitted to recipients falling under any of the following categories:

  1. data repository companies;

  2. companies providing bulk distribution of commercial notifications and bulk customer communication services.

Any recipients operating outside European Union process Personal data under EU Standard Contractual Clauses (SCCs) or under any other condition set out in the articles 44 – 49 of the GDPR (especially under adequacy decision). If you want to know what specific conditions are set out in your case, please contact us at privacy@smartlook.com.

Data storage period

We will process your personal data for the purpose of contract performance during the term of the contract, i.e. for as long as your user account exists and as is required by relevant legislation.

We will also process your personal data for direct marketing purposes for as long as your user account exists. However, if you opt out of offerings of our Smartlook.com products and features via your user account settings, we will cease to process the relevant personal data for these purposes even during the remaining term of the contract.

For data storage of personal data processed based on your consent, please see section 3 of this Privacy Policy.

Right to object to the processing of your personal data

You have the right to object to our processing of your personal data for direct marketing purposes at any time (see Purpose and legal basis of processing your personal data, point 2) above). If you object to our processing of your data for direct marketing purposes, we will cease processing your personal data for direct marketing purposes once we receive your objection.

You can send your objection to the processing of your personal data for direct marketing by email to: privacy@smartlook.com

In the objection, just indicate your username and include the text “I hereby object to the processing of my personal data for direct marketing purposes” and your signature. We will inform you without undue delay on how your request has been handled.

However, if you do not wish to receive our product and Smartlook.com feature offerings, it is always easier and faster to simply use the opt-out feature in your user account settings or click the "unsubscribe" link provided in each email containing our offerings.

Please note that the right to object cannot be exercised to make us stop processing the personal data we necessarily need to perform the contract or to fulfill our legal obligations.

Your other rights associated with personal data processing

You also have the right to:

  • ask for information as to which of your personal data are being processed,

  • request access to your personal data - at any time you can ask us to confirm whether or not personal data concerning you are being processed and if so, for what purpose, to what extent, to whom they are transmitted and for how long we will be processing them. You also have the right to obtain a copy of your personal data, with the initial provision of such data being free of charge,

  • request the erasure of personal data - at any time you may request the erasure of your personal data if (i) they are no longer necessary for the purposes for which they were collected or otherwise processed, (ii) the processing is unlawful, (iii) you have objected to the processing, and there are no overriding legitimate reasons for processing such data; (iv) we are obliged to do so under law; or (v) you withdraw the consent to processing you may have granted to us,

  • to obtain from us without undue delay the rectification of inaccurate personal data concerning you. You have the right to ask us at any time to correct any incorrect personal data or to complement your personal data if they are inaccurate or incomplete,

  • to obtain restriction of processing where for example you contest the accuracy of the personal data, the processing is unlawful and you oppose the erasure of the personal data and in other cases stipulated in the Art. 18 of the General Data Protection Regulation (restriction means that we will only keep and use the data with your consent or for the purpose of determining, exercising, or defending any legal claims),

  • object to the processing of your personal data if we process them on a legitimate interest basis,

  • to data portability - if we process your data in an automated manner and based on your consent or for the performance of a contract to which the data subject is party, in a structured, commonly used, and machine-readable format, you have the right to request that the data be transmitted directly to another controller,

  • contact us or the Office for Personal Data Protection if you have doubts as to whether we comply with our obligations inherent in the processing of your personal data.

You can exercise any of the aforementioned rights with us via our company’s Data Protection Officer by email at privacy@smartlook.com. We will answer your requests, questions, or comments within 1 month at the latest.

Our activities related to the processing of personal data are overseen by the Office for Personal Data Protection (www.uoou.cz) in Czechia, a member state of the European Union. This Office, just like yourself, will be informed if, despite our best efforts and all the data security measures in place, your personal data are leaked, misused, or lost.

CCPA

If you are located in California, the California Consumer Privacy Act of 2018 (“CCPA”) should apply. Please, see our separate document dealing with CCPA.

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