Effective Date: 22 November 2021
Last Updated: 22 November 2021
Information We Collect
When you use the Services, we collect the following types of information:
Information We Collect About You
We may collect automatic, anonymous information such as browser type and version, browser language, your operating system and platform, and the Internet Protocol (IP) address used to connect your computer to the Internet. This is called “Non-Personal Information” because it does not identify you, but is statistical data used for analytical purposes and helps us provide more relevant services to users. For example, we may use this information to administer and troubleshoot issues directly related to the Services, such as Site administration or to analyse certain trends in Site usage.
We use automated information collection tools, such as Cookies, Tracking Pixels, and Web Beacons, to collect certain types of Non-Personal Information
We may also collect anonymous information through the use of tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage and, in combination with a cookie, allows for the collection of information regarding the use of the webpage that contains the tracking pixel. We use tracking pixels to tell when you have clicked on certain website features or otherwise interacted with those features, and use that information to learn about visitor use. In some cases, we use third-party service providers to help us collect and analyse this anonymous information.
Web Beacons are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, and to monitor how many visitors view our Services. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages or in an e-mail.
Information You Provide
We collect several types of information from and about users of our Services. While you can use many features of the Services(s) anonymously, you may be required to provide certain types of personally identifiable information to gain access to some of our content or services. This information is called “Personal Information”, because it may be used to identify you, and may include, but is not limited to, your name, email address, mailing address, and phone number. For example, we may ask you to provide us with Personal Information that can be used to contact or identify you, including information that you provide by filling in forms on our Services. This includes information provided to use or receive information about services and offerings from Smart and Wise Limited. For example, when you fill out the “Register Now” form or “Contact” form,” you consent to release any Personal Information provided and/or data to us. Likewise, by submitting your Personal Information through the Services, you are consenting to receive e-mail or other applicable information from us.
You may choose to allow us to access your location by granting the Site access to your location when prompted or through your device’s location services settings. You may change these settings on your device. When you connect to the Services, we are able to recognise the IP address of the computer providing you with internet access. Our use of this IP address may be to help diagnose problems with our server or otherwise administer our Services. This IP address may also be used to gather broad demographic information. Your IP address is never associated with you as an individual and never provided to another company or organisation
Third-Party Social Networking Service(s)
If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Services, we may receive your Personal Information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Services to your contacts or to pull information about your contacts so you can connect with them on or through our Services. Some social networking services also will facilitate registration or enhance or personalise your experience on our Services. Your decision to use a social networking service in connection with our Services is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services
We may obtain Information, including Personal Information, from third parties and sources other than the Site, such as our partners or advertisers. If we combine or associate information from other sources with Personal Information that we collect through the Services, we will treat the combined Information as Personal Information in accordance with this Policy.
How We Use Your Personal Information
For Legitimate Interests. We do not sell or rent Information to any third parties. We use information collected by clickstream data collection, web pixels, and cookies to store your preferences, improve website navigation, make personalised features and other services available to you, to generate statistical information, monitor and analyse user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through the Site, and otherwise help administer and improve the Site.
We may identify you from your Personal Information and merge or commingle Personal Information and Non-Personal Information, for any lawful business purpose. Where you provide registration information, cookies can also be used to identify you when you log onto the Site. Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Site to you, including, but not limited to:
- To present our Services and their contents to you.
- To fulfill the purpose for which you provide it.
- To provide you with information or services that you request from us, such as sending you certain information about Smart and Wise’s services and offerings or processing purchasing or subscription requests.
- To evaluate and improve the content of our Services.
- To customize the Services to your preferences.
- To establish accounts and/or subscriptions to use the Services.
- To notify you of any changes to relevant agreements or policies.
- To enforce our agreements, terms, conditions, and policies.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Smart and Wise’s assets, where Personal Information held by Smart and Wise about our Services’ users is among the assets transferred.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- For other purposes identified to you and as requested by you (please note that you have the right to withdraw your consent to such use at any time by contacting us via the contact information below).
With the Consent of a Data Subject within the European Economic Area; or without consent, if a citizen of any other jurisdiction. If you are a Data Subject within the European Economic Area, and we have obtained your consent, we may also use your information in the following ways; and, if you are a citizen of any other jurisdiction, you acknowledge that we may use your information in the following ways:
- To send e-mail and postal mail to provide you with updates and news.
- To process any request you make.
- To process any commercial transaction, including but not limited to fulfilling an order or subscription request.
- To process your Personal Information as described throughout this Policy.
- To establish your account to use the Site.
- To validate your username, e-mail, password, and/or other login credentials.
- To respond to your requests.
- To provide you with merchandise you have requested.
- To fulfill your subscription purchase(s).
- To send you e-mail and postal mail supplying you with the most recent service information or to send you information about your order (e.g., order confirmations, shipment notifications, etc.).
- To notify you of any changes to relevant agreements or policies.
- To process your Non-Personal Information as outlined as described throughout this Policy.
We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and the Site. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and the Site.
We may anonymise or aggregate Information that we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other users.
How We Share Information
We do not sell or rent Personal Information to marketers or unaffiliated third parties. We do have relationships with trusted third parties, but we will not share any Personal Information that we have collected from or regarding you except as described below:
- Service providers that help us administer and provide the Site (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable data privacy laws and regulations and to use the Information only for the purposes for which it was disclosed. We require that any third-party service providers limit their use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorised use or disclosure of the Information.
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
- Pursuant to your explicit approval prior to the disclosure.
How We Protect Information
We have taken commercially reasonable precautions to protect the data and information under our control from misuse, loss, or alteration. Our security measures include industry standard technology and equipment to help protect your data. Unfortunately, considering the open nature of the internet, no system can ensure complete security and you should take steps to protect your information and transmissions to the Services.
If at any time after registering for information, you change your mind about receiving information from us, send us a request specifying your new choice. Simply send your request to firstname.lastname@example.org.
Your Choices, Access, and Rights to Your Personal Information
If you reside in certain jurisdictions, such as the European Economic Area, you may also have the following rights and options with regard to accessing, reviewing, correcting, and updating your Personal Information, as well as how we use and disclose your Personal Information:
Right to Access. We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Information.
- How to Access Your Personally Identifiable Information. You may choose to access or update your Personal Information as it exists in our records by logging into the account you have created for yourself on the Site, if applicable.
- Access to Personal Information. You may choose to access your Personal Information by contacting us and requesting access, a process which shall include our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Updating Communications Preferences (Opt-Out Policy). We do send e-mails to Users with information about our Site that we believe may be of interest. Users may opt out of receiving e-mail messages by contacting us via e-mail at email@example.com or by clicking on the “unsubscribe” link found at the bottom of every e-mail that we send. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you important administrative messages that are required to provide you with our Site’s services, as applicable. If you do not opt-out using the link at the bottom of an e-mail, you will continue to receive electronic communications until you choose to click on the link that will be provided in each e-mail you receive from us.
Right to Rectify — Correction and Deletion. Citizens of some jurisdictions, including the European Economic Area, have the right to correct or amend their Personal Information if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at firstname.lastname@example.org.
Right to Erasure / Be Forgotten. Data Subjects of the European Economic Area may have the right to request that we delete your Personal Information in certain circumstances, such as if holding the Personal Information is no longer necessary or if part of your Right to Object (below).
Right to Object. Data Subjects of the European Economic Area may have the right to object to the use of Personal Information for direct marketing uses, scientific uses, or historical research. If you do not wish to have your Personal Information shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile).
Right to Restrict Processing. Citizens of some jurisdictions, including the European Economic Area, have the right to request that we stop processing their Personal Information.
Right to Data Portability. Data Subjects of the European Economic Area have the right to request that we provide your Personal Information for the purpose of sharing it with another service provider (through a secure process).
Data Protection Officer
If you have an inquiry regarding your Personal Information, pursuant to the rights listed in the preceding section (above), please contact our appointed Data Protection Officer. You can send your message to email@example.com.
Links to Third Party Sites
Children Under the Age of 13
We do not sell products or services for purchase by anyone under the age of 13. In accordance with the Children’s Online Privacy Protection Act (COPPA), we will never knowingly request or solicit personally identifiable information from anyone under the age of 13, without verifiable parental consent. In the event that we receive actual knowledge that we have collected such personal information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.
Compliance with Legal Process
Please be aware that we will release specific Personal Information about you if required to do so in order to comply with applicable law or any valid legal process such as a search warrant, subpoena, statute, or court order. We may also choose to establish or exercise our legal rights or defend against legal claims.