1. General Provisions.
These Provisions (hereinafter referred to as the "Privacy Policy") apply to the SMARTon Service
Personal data means information or a set of information about an individual who is identified or can be specifically identified.
According to the Privacy Policy, the concept of "personal information" includes information or a portion of information that allows to identify the User/Customer.
As a rule, this information shall include first name and surname, nickname (nickname), email address (for minors – email address of a legal representative), and may also include information such as IP address, country and city of residence.
Such information can be obtained directly from the User/Customer, for example, when registering on the Website, providing contact information, information related to a bank card or payments, as well as other personal information that the User/Customer voluntarily provides to the Licensor/Contractor.
SMARTON-FZCO (Registration number DSO-FZCO-22732) has great respect for the confidential (personal) information of all persons, without exception, who have visited the Website, as well as those who use the services provided by the Website; therefore, SMARTON-FZCO seeks to protect the confidentiality of personal data (information or a set of information about an individual who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the services of the Website for each Customer/User.
Please note that filling out a personal account is not mandatory.
2. Use and Purpose of Personal Data Collection.
The personal information of the Website visitors collected upon registration is mainly used to provide services in accordance with the needs of the User/Customer, primarily in contractual relations.
The Licensor/Contractor may also use the User's/Customer's contact information in postal, including electronic, communications, namely, to inform about new opportunities, promotions, and other news.
The User/Customer may withdraw their consent to receive the newsletter at any time.
Upon receipt of the User's/Customer's consent to analyze the audience of the Customers/Users, their progress and compile rankings, the Contractor/Licensor will be able to offer the Customers/Users tasks that meet their level and needs, including for compiling rankings.
Such information can also be used for analytical purposes in an aggregated form, which can be obtained based on the above audience analysis.
The Licensor/Contractor may also create reports and analyses for research or business intelligence purposes, for example, to track potential issues or trends in their Service or to test new features and content of the Service.
Also, the Licensor/Contractor may use personal data to establish and maintain communication between the Customer/User and the Service or to provide advice on the provision of access services to the Service.
The Licensor/Contractor shall act in accordance with this Privacy Policy.
The Licensor/Contractor may store Personal Data as long as necessary to fulfill the purpose specified in this Policy or until the User/Customer deletes this data.
3. Providing Access to Information.
Access to personal information may be provided to other companies and individuals only in the following circumstances:
- The User/Customer's authorization is in place. The explicit consent of the User/Customer is required to transfer any confidential information.
- In cases of preventing a crime or damage to us or third parties.
The Licensor/Contractor reserves the right to transfer data to third parties providing services required for the processing of personal data and/or sending notifications or collecting reports for further analysis to achieve research or business intelligence purposes.
4. Information from External Accounts.
The Licensor/Contractor may allow logging in and authorization via accounts created on external products and platforms, such as Google or Apple (hereinafter referred to as the "External Accounts"). Should access to the SMARTon Service be provided through the External Accounts, the Licensor/Contractor shall collect from the Customer's/User's External Accounts the Personal Data to which they have granted access, such as name, e-mail, personal profile data, etc.
Personal Data shall be initially collected by the External Account operator and provided in accordance with its privacy policy. Generally, the Customer/User can control access to their personal data received by the Licensor/Contractor from these sources by means of the confidentiality of the Customer/User's external account.
When making payments by the Customer/User within the SMARTon Service, the Licensor/Contractor shall use external payment systems instead of storing the Customer’s/User's bank card details independently.
5. Information Protection.
The Licensor/Contractor shall take all necessary measures to protect the data from unauthorized access, alteration, disclosure or destruction. These measures shall include, but are not limited to, internal review of data collection, storage and processing procedures and security measures, including appropriate encryption and physical data security measures to prevent unauthorized access to systems that store personal data.
6. Cookies Policy.
A cookie is a piece of data that can be stored in a browser or on a mobile device that the Customer/User uses to access the SMARTon Service. It allows the Service to "remember" activities or preferences over a certain period of time or during a certain session.
Some cookies used by the Licensor/Contractor have been developed and used to facilitate the process of providing the SMARTon Service (essential cookies). The Licensor/Contractor has developed and uses basic cookies to verify the authenticity of users, block the illegal use of login credentials and prevent unauthorized access to user data.
The Licensor/Contractor may also use other cookies. They help you evaluate and understand how the SMARTon Service and its features are used and how they can be optimized. The Licensor/Contractor uses cookies to optimize advertising campaigns and to evaluate performance and analytics or to conduct business research.
Other cookies are used for performance measurement and analytics or for business research, for example, Google Analytics, Yandex Metrica.
The Licensor/Contractor also uses session cookies and persistent cookies. Session cookies are temporary cookies that are not stored in the browser or on the mobile device after a particular session. They are used for authentication and security purposes and to ensure that the SMARTon Service functions operate efficiently and as required.
The Licensor/Contractor may also use session cookies to save the Customer's/User's preferences while using the SMARTon Service. These session cookies are deleted when you log out the Service.
Persistent cookies are cookies that are placed in your browser or mobile device for a certain period of time after using the Service.
The Customer/User can disable tracking by cookies in their browser settings.
If the Customer/User prohibits the Licensor/Contractor from installing cookies, this may limit the functionality of the Service, which will make some of its functions unavailable to the Customer/User.
With the consent of the Customer/User, the Licensor/Contractor may send them notifications about their classes or other push notifications related to the SMARTon Service using the services developed for this purpose.
The Licensor/Contractor provides an additional feature within the SMARTon Service, namely, Customer/User rankings for the Customers/Users to compete with other Customers/Users from around the world. Such rankings may contain Personal Data of the Customers/Users under the age of 16. Personal Data of the Customers/Users under the age of 16 shall be provided only by their legal representatives.
7. Rights of the Personal Data Subject.
The Customer/User has the right:
1) to be informed about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give appropriate instructions to obtain this information to persons authorized by them;
2) to receive information on the conditions for granting access to personal data, including information about third parties to whom their personal data is transferred;
3) to access their personal data;
4) to receive a response on whether his/her personal data is processed no later than thirty calendar days from the date of receipt of the request, as well as to receive the content of such personal data;
5) to submit a reasonable request to the personal data controller with an objection to the processing of their personal data;
6) to submit a reasonable request to change or destroy their personal data by any owner and controller of personal data if this data is processed illegally or is unreliable;
7) to protect their personal data against unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to prevent the provision of information that is inaccurate or discrediting the honor, dignity and personal goodwill;
8) to apply legal remedies in case of violation of personal data protection legislation;
9) to make reservations regarding the restriction of the right to process their personal data when giving consent;
10) to withdraw consent to the processing of personal data;
11) to be informed about the mechanism of automatic processing of personal data;
12) to be protected against an automated decision that has legal consequences for them.
8. Amendments to the Privacy Policy.
The User/Customer accepts the terms and conditions of this Privacy Policy and takes into account that this Privacy Policy may be amended from time to time. Any amendments to this Privacy Policy shall be posted on this page.
Should the User/Customer have any questions regarding the Privacy Policy (including the deletion of personal data), they can contact us using the following e-mail address: smarton.international@gmail.com
After sending a request to get their data deleted, the Licensor/Contractor shall permanently and irrevocably delete personal data from their systems, including backup copies. After deletion, the data, including the personal account, of Customers/Users cannot be restored.
9. Contact information:
SMARTON-FZCO
Registration num. DSO-FZCO-22732
Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates
e-mail: smarton.international@gmail.com
