Smarp Privacy Policy

This Privacy Policy was last revised on August 22nd, 2016.

The Smarp online service (later referred to as Smarp or the Service), including a web site and in some cases other components, is owned and operated by Smarp Oy. (Later referred to as “Smarp”). Our Privacy Policy is designed to assist you in understanding how we collect, use, and disclose information we receive from individuals through the Service or when they visit our web sites.

This Privacy Policy may be updated from time to time. We will post any material changes via the Service or otherwise provide you with notice of any such changes. You are advised to consult this Privacy Policy regularly for any changes. Unless otherwise defined, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use (or Terms).

General Structure

When using the Service you should know that, as further explained in the Terms of Use, your Company Instance is defined by your company’s or organization’s email domain. Only those in your Company Instance can view other member profiles and feeds on the Company Instance. Smarp’s Administrative tools do allow our employees to view messages in a network to troubleshoot specific
issues, maintain and improve the Service or perform other Service-related functions, or as may be required by law. For further details on using the Service, please refer to our Terms of Use.

Information collection and storage

Smarp collect non-sensitive personal information, such as name, email address, favourite content topic of users; and company-related configuration, such as URL subdomain prefix for Company Instance (e.g. CompanyName.smarp.com), default invitation message, etc. If you choose to post User Content, you should be aware that any Personal Information you submit through these features can be read, collected, or used by other viewers of your Company Instance.  We are not responsible for the Personal Information you choose to disclose on the Company Instance or with the members of your Company Instance.  The above-mentioned data can be input directly into the platform by the client, or the users, or provided to Smarp by the client.

Smarp are not responsible for the non-sensitive personal information users choose to disclose on the Company Instance or with the members of the Company Instance.

All of the above-mentioned information is categorized as “client’s data”, and stored in Ireland and/or Belgium with clear policy on how to securely access it, and with the respect to EU Data Protection Directive 95/46/EC. Users personal information and authentication codes are stored in Smarp production server, to which only a limited number of privileged Smarp personnel has access.

Site Usage Information

Cookies

Like many websites and webapps, we use “cookies” to collect information.  We use cookies for two purposes.  First, we utilize persistent cookies to save your registration information for future logins to the Service.  Second, we utilize session ID cookies to enable certain features of the Service, to better understand how users interact with the Service or user Content, and to monitor aggregate usage by users and web traffic routing on the Service. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Service and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of, or have access to all functionality of, the Service.

Web beacons

We also use “web beacons,” “pixel tags,” “clear GIFs” or similar means (individually or collectively “Web Beacons“) in our Service.  A Web Beacon is an electronic image, often a single pixel, embedded on web pages.  Web Beacons are ordinarily not visible to users.  Web Beacons allow us to count the number of users who have visited certain pages of the Service or interacted with content shared by users, to deliver branded services and to generate statistics about how our Service is used.

Log data and behavioral tracking

When you interact with the Service, it automatically records information that your browser sends whenever you visit a website or perform certain actions (“Log Data“). This Log Data may include information such as your computer’s Internet Protocol address, browser type, the webpage you were visiting before you interacted with our Service, your actions, and other statistics. We use this information to monitor and analyze use of the Service and for the Service’s technical Administration, to increase our Service’s functionality and user-friendliness, and to better tailor it to our users’ needs. Such information may also be used to gather broad demographic information, such as country of origin and Internet Service Provider. We may also link this information with Personal Information. These data is categorized as “Smarp’s data”, might be stored and processed by 3rd party service providers, and is not subject to datacenter geolocation requirement, if any, but can be anonymized upon request.

Use and Disclosure

Personal Information

We use your Personal Information to provide, maintain, protect, and improve the Service, to authenticate you as a user, to communicate with you, to assist you in using the Service, and allow your company to track and measure the publicity you generate related to the company and its products. We may combine your Personal Information with non-Personal Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Service, and to analyze and understand how our Service is used. Smarp will not share, rent, or sell your Personal Information to other parties, except to our service providers as set forth below.

We may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources, including (without limitation) any of our other websites and third parties. We may send you notices (for example, in the form of emails, mailings, and the like), and otherwise correspond with you, about products, services, companies, events, sponsored by us and others, that we think might interest you.

We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our Service to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user. Information relating to aggregate statistics may be collected through the use of third-party cookies and other third party tracking devices.

Social Media Platforms and Third-Party Websites

We may share the information in your account, and user Content you elect to share via the Service, with the Social Media Platforms with whom you choose to share user Content, provided the Social Media Platform has been approved by an Admin of your Company Instance. By publishing user Content to your Social Media Platform, you are allowing us to access your Social Media Platform account information and you are agreeing to the applicable Social Media Platform terms and conditions. Other than what we may share with a Social Media Platform in connection with your use of the Service, the Personal Information a Social Media Platform has collected from you is obtained and maintained by them independently of our Service.  Other services follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use. We cannot always foresee or anticipate technical or other difficulties which may result in failure to obtain data or loss of information, personalization settings or other service interruptions. We cannot assume responsibility for the timeliness, accuracy, deletion, non-delivery or failure to store any Social Media Platform data, communications, or personalization settings.

When you are on this website you may have the opportunity to visit, or link to, other websites, including other websites operated by Smarp or by unaffiliated third parties. These third-party websites may collect Personal Information about you, and because this Privacy Policy does not address the information practices of those other websites, you should review the privacy policies of such other websites to see how they treat your Personal Information.

Third-Party Service Providers

We may employ agents, contractors, and third-party companies and individuals to operate the Service and perform related services (e.g., operation and maintenance of the Service, database management, web analytics, and improvement of the Service’s features), or to assist us in analyzing how our Service is used.  These third parties have access to your Personal Information and other information collected as set forth above only to perform these tasks on our behalf and are obligated not to disclose your Personal Information or use it for any other purpose.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Smarp, its suppliers, or other third parties, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

Business Transfer

We may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Comments, Feedback, Surveys

If you email us through the website, we may ask you for information such as your name and email address so we can respond to your questions and comments. If you choose to correspond with us via email, we may retain the content of your email messages, your email address and our response to you. In certain cases, and with your permission, we may post content from your emails to us on the website.

We may occasionally ask users of our Service to complete online surveys and opinion polls about their activities, attitudes, and interests. These surveys help us better serve you and improve the usefulness of the Service. In requesting your participation in these surveys we may ask you to provide you name and email address to us.

Security

Smarp is ISO27001:2013 certified. We take security very serious, Smarp has dedicated person for security “Chief Security Officer”, with clear and well implemented information security policies. Smarp uses commercially reasonable and industry standard safeguards to preserve the integrity and security of your Personal Information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting via the Service in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement, or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. We restrict access to personal information to those employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations. While Smarp endeavors to protect the security and integrity of sensitive Personal Information provided to the Service, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be safe from intrusion by others, such as hackers. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

International Transfer

Your information may be transferred to, and maintained on, computers located outside of your country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

Our Policy Towards Children

This Service is not directed to children. We do not knowingly collect Personally Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us. If we become aware that a child has registered for the Service and has provided us with Personal Information, we will delete such information from our files.

Contact Us

If you have any questions or comments about this Privacy Policy, please contact us at:

Smarp Oy
Hiililaiturinkuja 2,
00180 Helsinki
Finland
Email: support@smarp.com

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