Last updated October 1st, 2020.

Please read the following information carefully before providing your personal data.

This document concerns the manner and scope of processing the personal data of you as a natural person. 

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  

privacy@smartlook.com 

Personal data processed

We will only process the personal data you provide to us while setting up your user account, when using Smartlook.com via the Smartlook.com access interface, or when you, as the account owner, will be setting up your access to the user account, it being understood that in this context, the Controller will specifically process the following personal data concerning you:

  • name and surname
  • address
  • job title
  • 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 data for the purpose of contract performance

Purpose and legal basis of the processing of 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 by registering and setting up your user account at Smartlook.com. The legal basis 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) 

The processing of your personal data, which is necessary for the performance of the contract to which you are a party, will be done in the following manner.

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.

2. Processing for the purposes of direct marketing

Purpose and legal basis of the processing of the following personal data:

  • name and surname
  • email address

We process these personal data for the purpose of direct marketing, which constitutes a legitimate interest of our company. The legal basis in this case is Art. 6(1)(f) 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). 

The data processing based on our legitimate interest, specifically direct marketing, 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 offerings, whether these involve new features or existing products and Smartlook.com service extensions. 

In this case, the purpose and legal basis of the processing of your personal data is the Controller’s legitimate interest of direct marketing, specifically the direct offerings of our products and Smartlook.com service features we will be sending to you. 

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.

Please note that as part of the contract, specifically in the context of the processing under point (1), 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; they do not constitute direct marketing notices and you may not opt out of them.

3. Processing undertaken to improve our customer support

Purpose and legal basis of the processing of the following personal data:

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 behaviour 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. The legal basis in this case is Art. 6(1)(a) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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). 

The processing of these personal data concerning you, which will only happen with your consent, will take the following form.

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 know the language you want us to use in communication with you. 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.

We track visitor activity and behaviour at Smartlook.com every time you access the site and the resulting data allow us to provide more effective user support if you need any help or advice using Smartlook.com. 

In this case, the purpose and legal basis of the processing of your personal data is the consent you have granted to us.

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.

In all cases, we will process your personal data manually and 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 the confidentiality obligation.

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.

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. 

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 your personal data, including during the remaining term of the contract.

We will process your personal data processed 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 them as long as your user account exists. Furthermore, we delete individual track recordings concerning your activity and your behaviour at Smartlook.com after 30 days at all times.

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 user name 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. 

Your other rights associated with personal data processing

  • ask for information as to which of your personal data are being processed,
  • request access to such data and have then updated or corrected - 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. 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.
  • request the erasure of such personal data or have the processing of such data restricted - 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 to do so under law; or (v) you withdraw the consent to processing you may have granted to us. We will restrict the processing of your personal data until we have resolved any disputable issues regarding the processing of your personal data (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 for direct marketing purposes or on a legitimate interest basis.
  • to data portability - if we process your data in an automated manner and based on your consent or under an agreement, in a structured, commonly used and machine-readable format, you have the right to request that the data be transmitted directly to another controller
  • if you have doubts as to whether we comply with our obligations inherent in the processing of your personal data, contact the Controller or the Office for Personal Data Protection.

You can exercise these 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.

How do we use cookies?

When using Smartlook services and products, temporary files, so-called "cookies", may be stored, which may contain information capable of identifying the user. No personal data are stored in the cookies.

SL_C_23361dd035530_KEY - this is the project key, specific to each project that you add to your Smartlook dashboard

SL_C_23361dd035530_SID - this is the session ID, that is assigned to each new session that is being recorded

SL_C_23361dd035530_VID - this is the visitor ID, assigned to each new visitor. 

The cookies can be deleted manually by clearing browsers cache

AWSELB Cookie: Cookie AWS creates for efficient Load Balancing. More info on AWSELB here: https://docs.aws.amazon.com/elasticloadbalancing/latest/classic/elb-sticky-sessions.html

Data Protection Officer

We have appointed a Data Protection Officer to enhance data protection.  The Data Protection Officer at our company is Richard Schmidt, Attorney at Law. You can contact him at dpo@smartlook.com.

Did this answer your question?