Privacy Policy

At SMART GROUP SYSTEMS INTERNATIONAL, LLC and all our subsidiaries (“SMART GROUP SYSTEM”, “us”, “we”), we are fully committed to the privacy of the users of our website. That’s why we have drafted this Privacy Policy – so you can understand how seriously we take your privacy and the protection of your personal data.
By reading this Policy, you will be able to understand how we handle the personal data we may collect when you use our website, and make informed choices about how we may process your personal data – in particular, reading this Policy will allow you to provide your consent in an informed manner, where this is needed.

All personal data we collect on the users of our website is handled in a lawful, fair and transparent manner. We follow internationally recognized principles on this, such as the principles of purpose limitationstorage limitationdata minimizationdata quality, and confidentialty.

Data Controller

We are a data controller of all personal data that is collected and processed through our website.

For any questions related to this Privacy Policy, please contact: privacy@smartgroupsystem.com

Personal data processed

When you visit our website, we collect and process some personal data related to you, both when you decide to actively provide it to us (such as when you sign up to subscribe to our newsletter), and by analyzing your behavior on the website.

Name, contact details and other Personal Data

In various sections of the website (such as when request a quote, or sign up to our newsletter), we require you to send us some of your personal data, such as your name, phone / mobile number, e-mail address and information related to your employer, such as its name and your position.

Special categories of personal data

Our website includes free text fields so you can send us messages (for example, the Live Chat or contact function), as well as sections where you can post various types of content. You might include (whether on purpose or not) some of your own personal data within those messages or posts, including special categories of personal data.

We ask you to not disclose any personal data in the messages that you send to us or in any posts you make (particularly special categories of personal data!), unless you feel that this is strictly necessary. If you decide to do so, we will collect and process those personal data only where we believe we are legally allowed to do so, in order to address your message or post.

Personal data of other persons

Just as we explained above, the free text fields on our website can be used to send us messages or post various types of content. You might also include (whether on purpose or not) personal data related to other persons within those messages and posts.

If you disclose personal data of other people to us through our website, you will be considered as an independent data controller regarding those personal data. This means you will be held fully responsible for ensuring that you are allowed to disclose those personal data to us (for example, because the other people have agreed to this, or because you are legally required to do so). If you are not allowed to disclose those personal data to us, then you may be required to compensate us in full for any damages or costs we suffer because of this – for instance, as a result of complaints brought against us, or lawsuits filed against us.

Browsing data

Our website uses computer systems and software procedures that collect browsing data about users of the website, which includes your IP address, location, and more. We don’t collect this information to link it to specific users (though it is possible to identify specific users, using browsing data alone or by matching browsing data with other information we have). These browsing data are used to compile statistical information on the use of our website, make sure it works properly, and make sure that our website is not abused.

Cookies

What are cookies?

Cookies are small text files that are sent and registered on your computer by the websites that you visit. These files are then re-sent by your computer to the same sites, when you visit them again.
Cookies allow websites to “remember” your actions and preferences (such as login data, language, font size, browsing activities and more). The information collected by cookies can be used for a wide variety of purposes, including to ensure that you don’t need to reconfigure settings when you visit a website again (or when you change pages within the same site), to keep you logged in to your account, to gather information about how you use a website, and to display advertisements on a website which may interest you.
There are different types of cookies that you may receive when browsing a website, which can be classified based on their purpose. These include techinical cookies, browsing / session cookies, and function cookies (all of which usually don’t require your consent,) analytics cookies and profiling cookies (which usually require your consent).

Cookies can also be divided into first-party cookies and third-party cookies, depending on whether they are sent to your computer and managed by the owner of the website, or by someone else.

What cookies do we use ?

We use the following types of cookies:
– Browsing and / or Session Cookies
– Analytics Cookies
– Profiling Cookies

We also use third-party cookies on our website. Please see a list of the third parties who may place cookies on your computer through our website below. For more information on these cookies, including how to block or opt-out of specific third-party cookies, see the links included in the Privacy Policy / Opt-Out Mechanisms column:

Google (Google Analytics) 
https://policies.google.com/technologies/ads
https://policies.google.com/privacy
https://tools.google.com/dlpage/gaoptout

Our website uses Google Analytics. Analytics is a tool developed by Google that collects information allowing for your use of the site to be evaluated, analyzed and is meant to improve your browsing experience.

You can block or delete the cookies used on our website via your browser options. Your cookie preferences will be reset if use change the browser you use to access our website. For more information on how to set the preferences for cookies via your browser, please refer to the browser provider you use.

If you block or delete the technical and/or function cookies used on our website, it may not be possible to browse our website and/or some of the functions of our website may not be available. In this case, you may need to manually enter your information and preferences each time you visit our website.

Purposes of the processing

We use your personal data that we collect through the website for the following reasons:

Services

When you request a quote from us or send us a message, we will use the personal data you provide in order to address your request and respond to you. In general, whenever you ask us to provide any services to you through the website, we will use the personal data you share with us to address your requests.

Compliance

When we collect your personal data, we may be required to store it for a certain amount of time, or report it to official authorities, because we are legally required to do so. This may be the case, for example, where we are required to retain or report your data to official authorities in order to meet tax, customs or other legal obligations.
We only handle your data in this manner where this is strictly necessary in order to comply without legal obligations.

Analytics

We can collect information on the manner in which you interact with our website, such as the pages you visit and how much time you spend on each page, through the use of analytics cookies. We will use the information collected to improve our website, as well as the services we offer on the website.
We only use your personal data for these purposes if you consent to this, by accepting the use of analytics cookies on our website (through the pop-up banner you have been shown, at the top of our website).

We can analyse the browsing data and other information collected on how you and others use our website, in order to ensure the security of our website, as well as detect and prevent any misuse of our website.
We use your personal data in this manner because we have assessed that we have a legitimate interest in ensuring the security of our website and preventing the use of our website for potentially criminal purposes.

Recipients of personal data

Your Personal Data may be shared with other following people/entities (Recipients):

  • People, companies or firms that provide us with advice and consultancy concerning accounting, administrative, legal, tax, financial and debt collection matters in connection to our services
  • Entities that help us provide our services such as hosting providers and email platform providers
  • Public entities, bodies or authorities with whom we share personal data, when strictly required by law (such as local tax, customs or law enforcement authorities).

Retention of personal data

Retention for Marketing Purposes

We will keep your data that we process for marketing until you unsubscribe or opt-out of such communications. If you decide to opt-out, we will not use your data for marketing purposes anymore; however, we may need to keep it for longer if we have an existing business relationship with you, or in order to protect ourselves from liability (in this case, under restricted conditions of use).

Retention for Profiling Purposes

We will keep your data that we process for profiling purposes from the moment you give us your consent until the moment you withdraw such consent. Once you withdraw your consent, we will no longer use such data for profiling purposes, but may need to keep it for longer in order to protect ourselves from liability (in this case, under restricted conditions of use).

Retention for Compliance Purposes

We will keep data we process as long as required by the specified obligation or by the applicable law

Retention for Analytical and Misuse/Fraud
We will keep data we process for as long as necessary to fulfil the proposes for which we collected it unless you object to the processing of your data for these purposes (see Section 8 for instructions on how to object).

Data rights / Your rights

As a data , you can exercise the following rights at any time:

  • Access your personal data that we are processing (or receive a copy of those personal data) and obtain information about such processing
  • Correct or modify your personal data that we are processing when it is inaccurate or incomplete
  • Request that we erase your personal data that we are processing when you feel that the processing is unnecessary or unlawful
  • Request restriction of the processing of your personal data when you feel that the personal data we have on you is inaccurate, unnecessary or has been unlawfully processed, or when you have previously objected to its processing
  • Exercise your right to portability: you can request a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format, and you can request that those personal data be transmitted to another data controller
  • Object to our processing of your Personal Data, based on relevant grounds that are related to you and your situation, which you believe should prevent us from processing your personal Data
  • Withdraw your consent to processing (for Analytics or Profiling).

    You can exercise any of the rights mentioned above by sending a written request to: privacy@smartgroupsystem.com

You can also object to the processing of your personal data for Marketing, without needing to provide any justification for this, by selecting the appropriate link included at the bottom of marketing e-mail messages. You can also withdraw your consent for Profiling or Analytics by blocking or opting-out of the profiling/analytics cookies used on our website (see “How can I change my cookie settings?”).

As a data object, you are entitled to file a complaint with the competent supervisory authorities for the protection of personal data, if you believe that the processing of your personal data carried out through our website is unlawful.