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PRIVACY POLICY



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SMARTE PRIVACY POLICY

‍SMARTe Inc. (“collectively known as SMARTe) is the world’s Data-As-A-Service
platform for sales and marketing.  We understand that you care about how
information about you is used. This privacy policy describes how SMARTe manages
personal information collected, received, or maintained. We collect information
pertaining to businesses and business people (“Business Information”) and all
other types of information through our website and other online services (the
“Site”).

At SMARTe Inc., we take utmost care to protect your privacy. This privacy policy
pertains to the different means of how we collect your information and describes
how your personal information is stored and treated.

For residents of the State of California, please click here to find out more
about your rights under the California Consumer Privacy Act of 2018 (“CCPA”).


‍SMARTE WEBSITE

‍You may access and browse this website without revealing any of your personal
information. However, while downloading any of our material which have been
developed by our internal Subject Matter Experts OR while subscribing to our
blogs/newsletters OR while filling in a demo request form, we may collect your
personal information such as your name, phone number or e-mail id that may be
necessary to help us provide better customer service and we maintain the highest
levels of confidentiality pertaining to your information.

This portion of the policy applies to the Website. It does not apply to any
website of any third party, even if the third-party website links to (or is
linked from) the website. By accessing, using, and/or submitting information
through the Website, you consent to the practices described in this policy with
regard to the information collected thereby as described herein. If you do not
agree with this policy, you must delete all cookies from your browser cache
after visiting the website and refrain from visiting or using the website.


‍HOW DOES SMARTE COLLECT WEBSITE VISITOR INFORMATION?

‍To browse the Website only, you are not required to provide any personal
information. However, we may gather non-personally-identifiable information.
Similar to many commercial websites, we utilize “cookies” and other technologies
to collect non-personally-identifiable information on visitors to the Website.
Cookies allow web servers to recognize the computer used to access a website.
Cookies store information accessed through your browser to streamline activities
on related web sites, and make the online experience easier and more
personalized. Information gathered through cookies and web-server log files may
include information such as the date and time of visits, the pages viewed, IP
addresses, links to/from any page, and time spent at a site.

Information collected from Website submissions will be used for SMARTe’s
internal business purposes, including its investigations, sales, and marketing.
We may use IP addresses for purposes such as calculating usage levels,
diagnosing server problems and administering the Services. We may also derive
your approximate location from your IP address.

The website may include options for visitors to submit information to SMARTe,
for example, to request a product demonstration, download an article, etc. Such
forms may provide the option of submitting personal information, such as your
name, job title, company, email address, or phone number. In addition, when
submitting information on a Website, your submission will be associated with the
IP address you are then using, which is automatically assigned to your computer
by your Internet Service Provider.

If you have visited any of the Website and would like to know what information,
if any, SMARTe has about you and would like to correct such information or have
it deleted, you may contact us at privacy@smarteprivacy.com. If you do not want
us to contact you via phone, you can email us at privacy@smarteprivacy.com with
“Do not call” as the subject line and we will opt you out.


‍HOW DOES SMARTE COLLECT CUSTOMER INFORMATION?

‍Visitors to our Site may choose to submit their name, email address and/or
other information so that they can learn more about our services, register to
take part in a SMARTe-sponsored event, or participate in a survey, contest or
sweepstakes, among other things.

In order to use SMARTe products and services, you may be required to register as
a user. From time to time, we may use your email address to send you information
and keep you informed of products and services in which you might be interested.
You will always be provided with an opportunity to opt out of receiving such
emails. Your contact information may also be used to reach you regarding issues
concerning your use of our Site, including changes to this privacy policy.

You may be a user that has been provided access to SMARTe’s solutions through
your company license agreement. Your employer may require that one or more users
have global rights to access any and all information of every user that has
access through the company. If you have questions or concerns regarding the
rights of other individuals in your company to access your User Information,
Uploaded Information, or Usage Logs, you should raise those concerns with the
appropriate person at your company.

SMARTe gives you an option of buying subscription to SMARTe’s solutions via your
Credit Card. We will use that information solely for the purpose of fulfilling
your purchase request. We will store credit card information in an encrypted
form and will not sell, share or use it again without your prior consent. (The
only exceptions are described in the sections below on “Disclosures to Service
Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the
Company”).


‍HOW DOES SMARTE USE CUSTOMER INFORMATION?

‍Customer Information may be used for SMARTe’s legitimate business interests in
connection with your use of the Services, including to respond to user inquiries
and fulfill user requests, complete transactions, provide customer service, send
administrative information, and to personalize user experience with the
Services. We may use Customer Information to better understand our users in
general and to improve the content and functionality of the Services. We may use
Customer Information to contact you in the future to tell you about services,
promotions, opportunities, and other general information about SMARTe we believe
will be of interest to you. We may use Customer Information to investigate and
prosecute potential breaches of SMARTe security or license agreements.

SMARTe will not disclose Customer Information to any third party except in
connection with a legitimate use as set forth herein, in connection with a bona
fide legal dispute to which such information is relevant, in response to valid,
compulsory legal process, or as otherwise required by law. SMARTe will, whenever
possible, obtain confidentiality agreements from any person or entity to whom
Customer Information is disclosed and ensure any recipients are committed to
employing appropriate technological security measures.

SMARTe employs reasonable security and back-up procedures to protect Customer
Information. However, in the unlikely event there is a loss or corruption of
Customer Information, SMARTe is not responsible or liable for such loss or
corruption. We encourage our users to retain copies of all Uploaded Information
on their own system.

SMARTe will use Payment Information solely for the purpose of fulfilling
purchase requests. We will store Payment Information in an encrypted form and
will not sell, share, or use it again without prior consent.


‍HOW DOES SMARTE GET THE BUSINESS INFORMATION FOR ITS PRODUCTS?

‍“Business Contact Information” means any of the following information as used
in connection with an individual’s business or profession: Name, Title, Company
Name, Business Email Address, Business phone number, Work address, Public
professional profile address, and/or supplementary information such as business
role and responsibility designations.

Using next-generation focused crawling, SMARTe builds profiles of business
people and companies, which we call “Contacts” from different sources including
Corporate Websites, Annual Reports, Social Networks, Tradeshows, Conferences,
User Groups, Publications, Associations, News Releases, Technical Papers, List
Directories, Communities, Blogs, Press Releases, Company Reports, Trade
Magazines, Journals, Newsletters, Professional and Social Networking Sites and
Search Engines, etc.

Once we have collected business Information about a person or company, we
combine multiple mentions of the same person or company into a CONTACTS. The
resulting master of Contacts (the “MASTER”) is then made available to the users
of the Site and our customers and strategic partners.


‍SMARTE PRODUCTS AND SERVICES

‍SMARTe collects information regarding companies and their employees, including
Business Contact Information on company executives, decision makers, and other
employees. The information collected is like that which is typically included on
online professional profile, a business card, or business email signature etc.
including: name, company name, job title, business email address, business phone
number, business address, and corporate website URL. SMARTe gathers, verifies,
and organizes this data for purposes of licensing such information to SMARTe
clients and strategic partners for sales and marketing purposes.

SMARTe obtains data for its database from web crawling, first-hand research
including telephone interviews, publicly available resources, and third-party
licensors. All the business contact information that SMARTe obtains through any
of the foregoing means is verified by SMARTe’s technologies and in-house
research team, and information that is found to be inaccurate or irrelevant to
the purposes of the Services is removed and deleted. SMARTe endeavors to publish
highly accurate business contact information on influencers and decision makers
and other agents and employees of the companies it profiles.


‍THE GENERAL DATA PROTECTION REGULATION GDPR FOR EU RESIDENTS

‍Our data operations are guided by the principles of global privacy laws,
ensuring respect for individual privacy rights. As part of our commitment to
these principles, we regularly send opt-out notices to individuals in our
database, offering them the opportunity to have their information removed from
our master database in accordance with global privacy regulations. We are
committed to adhering to the key principles outlined in Article 5(1) of the
General Data Protection Regulation (GDPR).

We operate in a dual capacity:

Data Processor: We act as a data processor specifically for the user data
managed within our app. This involves handling user data according to our users’
instructions and in compliance with relevant data protection laws.

Data Controller: We act as a data controller for the master data we aggregate.
This includes collecting, storing, and using master data independently,
determining the purposes and means of processing this data.

SMARTe complies with the recent GDPR regulation by processing data along the
GDPR norms. Under GDPR there are six grounds to process personal data, these are
equally valid. There are two of these which are relevant to our business (direct
B2B marketing) they are: consent or legitimate interest. As Recital 47 of the
GDPR states that “The processing of personal data for direct marketing purposes
may be regarded as carried out for a legitimate interest.” Using legitimate
interest as the basis for B2B marketing involves ensuring key conditions are
met:

“The processing must relate to the legitimate interests of your business or a
specified third party, providing that the interests or fundamental rights of the
data subject do not override the business’ legitimate interest.”

“The processing must be necessary to achieve the legitimate interests of the
organization.”

Along with the above compliance, SMARTe DOES NOT share personal data with
customers / partners, RECORDS all data processing activities, DON’T SOURCE any
sensitive information such as religion, political inclinations, gender, age
etc., has an EXPLICIT OPT-IN, OPT-OUT process and is proud to be operating for
over 15 years without any data breach

As a ‘data processor’, SMARTe Inc. follows the following data privacy
requirements

As a ‘data processor’, SMARTe Inc. follows the following data privacy
requirements honoring the GDPR law (Article 13 and 14). SMARTe provides notice
to all data subjects as required by GDPR Article 13 or 14, as appropriate, and
honors the rights of data subjects provided in Articles 12-23, including the
right to be forgotten.

SMARTe informs individuals about the collection and use of their personal data,
retention periods for the data, and who it will be shared with. This is a key
transparency requirement under the GDPR, provides privacy information to
individuals at the time of collecting their personal data. When SMARTe obtains
personal data from other sources, we provide individuals with privacy
information within a reasonable period of obtaining the data and no later than a
month. If any EU resident information is sourced in SMARTe database then SMARTe
will provide such individual with a notice detailing the information SMARTe has
on such person, the purpose for which it will be used, and informing such person
of their rights with respect to such information, including the right to know
what information SMARTe possesses on them, to correct such information, or to
opt out of data collection entirely. Such persons may opt out of the SMARTe
database by emailing privacy@smarteprivacy.com.

Information we provide to people is concise, transparent, intelligible, easily
accessible, and in clear and plain language. We conduct regular review, and
where necessary, update our privacy information. If there are any new uses of an
individual’s personal data, we make sure to bring it to their attention before
we start processing.


‍DISCLOSURES OF PUBLIC PROFILES

‍We may make any Business Information that our users contribute for inclusion in
our Directory, that we collect from public web sources or that we license from
third parties available to users of the Site, to our strategic partners and to
our customers.


‍DISCLOSURES TO SERVICE PROVIDERS

‍SMARTe may from time to time disclose Business Information or other collected
information to service providers, solely for providing functions related to our
operation of the Site and for no other purpose. For example:

SMARTe uses service providers to process credit card payments on our Site. When
you use a credit card to pay for SMARTe services, information such as your name,
billing address, phone number, email address and credit card Information will be
submitted to service providers for verification and to manage any recurring
payments.

SMARTe uses software hosted by a service provider to provide us with information
regarding our visitors’ activities on our Site. When you visit our Site, that
service provider may set cookies on our behalf and may receive information about
your browsing activity on our Site.


‍DISCLOSURES FOR LEGAL REASONS

‍We may disclose collected information, including Business Information, to a
third party if we believe in good faith that such disclosure is necessary or
desirable: (i) to comply with lawful requests, subpoenas, search warrants or
orders by public authorities, including to meet national security or law
enforcement requirements, (ii) to address a violation of the law, (iii) to
protect the rights, property or safety of SMARTe, its users or the public, or
(iv) to allow SMARTe to exercise its legal rights or respond to a legal claim.


‍DISCLOSURES TO A BUYER OF THE COMPANY

‍If our company or substantially all of our assets are acquired, or in the event
of a merger or bankruptcy, information about you and/or information you provide
to SMARTe may be among the transferred assets. You will be notified via email
and/or a prominent notice on our Site of any change in ownership or uses of your
personal information, as well as any choices you may have regarding your
personal information.


‍OTHER DISCLOSURES

SMARTe Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  SMARTe Inc.
has certified to the U.S. Department of Commerce that it adheres to the EU-U.S.
Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union and the United
Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. 
SMARTe Inc. has certified to the U.S. Department of Commerce that it adheres to
the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles)
with regard to the processing of personal data received from Switzerland in
reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in
this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern.  To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/ 

SMARTe Inc. is subject to the investigatory and enforcement powers of the
Federal Trade Commission (FTC) 

We would like to inform individuals about the possibility, under certain
conditions, for the individual to invoke binding arbitration. 


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SMARTe Inc.
440 N Wolfe Road, Sunnyvale, CA 94085.
+1 (408) 834 8842