I. INTRODUCTION TO SMARTWALLET PRIVACY POLICY
This privacy policy (this “Privacy Policy”) describes how Smart Wallet Inc. and our affiliates (“Smart Wallet”, “we”, “our” or “us”) will collect, use, share and store your Personal Information that we collect in connection with your use of our website at https://www.smartinvestsas.com/ and any of its related or subdomains (the “Website”); in connection with your use of our platform/dashboard mobile software application and any other software application that we license (the “Platform”); where we act as the controller of your Personal Information (as such term is used in applicable data protection laws); and in connection with other occasions where we collect and process your Personal Information, as further detailed in this Privacy Policy.
For purposes of this Privacy Policy, “Personal Information” is information relating to an identified or identifiable individual. For purposes of this Privacy Policy, Personal Information does not include de-identified or aggregated information and, to the extent permitted by law, does not include publicly available information that is lawfully made available to the general public or information that is lawfully made available from government records.
This Privacy Policy does not apply to Personal Information collected from employees or candidates for employment with Smart Wallet.
II. PERSONAL INFORMATION COLLECTED BY SMARTWALLET
In order to provide you with the benefits of using our Website and Platform, Smart Wallet collects certain information about you.
Personal Information about You
The following chart describes representative types of Personal Information that we may collect about you, the circumstances in which this Personal Information is collected, and our purposes for such collection.
| Instances of Collection | Types of Personal Information | Purposes for Collection |
| When you browse or visit our Website | Cookies, analytic tools and log files (for more information, please see Section II.3 below) | — Marketing and website analytics to improve performance and user experience |
| When you request a free trial or a product demo | Contact Information (e.g. name, email address, company name, job title) | — Schedule a demo
— Send you communications related to the demo — Provide the demo — Send product and company news |
| When you join our Developer Portal and Community | Name, email address, company name | — Enroll free developer accounts
— Provide access to a testnet workspace in a sandbox environment — Provide access to the Developer Community |
| When you subscribe to our communications | Contact Information | — Add you to our mailing list to send you communications |
| When you download a white paper or other materials on our Website | Contact Information | — Send you the white paper or other materials available on our Website |
| When you register for a webinar that we host | Contact Information | — Allow you to register for the webinar
— Send you related communications — Provide you with the webinar |
| When you contact us (e.g. customer support) | Contact Information | — Process and answer questions
— Provide support — Customize your experience |
| When you create an account and log in | Contact Information | — Create your account and enable access to our Platform
— Allow you to log in to the Platform — Allow you to enjoy features available to registered users only |
| When you attend a marketing event | Contact Information | — Establish a business connection |
| When we acquire your data from third-party sources (e.g. lead-generation companies) | Contact Information | — Establish a business connection |
| When we use the data of our resellers, distributors, agents or finders | Contact Information | — Contact our resellers, distribution, agents or finders
— Perform/execute the agreement |
| When we use the data of our service providers | Contact Information | — Contact our service providers
— Perform/execute the agreement |
| When you interact with our social media profiles | Your social media profile details | — Respond to your request or question |
Information Collected from Your Browser or Device
We automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile phone, tablet or other device (“Device”) you use to access the Website. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We, and our third-party service providers may use a Device Identifier to, among other things, administer the Website; help diagnose problems with our servers; analyze trends; and track users’ web page movements over time.
In addition, we automatically gather and store certain information about your visit from your browser or Device, such as your browser type, operating system type, length of time on the Website, and how you got to the Website. We may collect this information through the use of server log files and other methods.
Information Collected using Cookies or Other Tracking Technologies
We collect certain information through tracking technologies used on the Website such as cookies (data files placed on a Device when it is used to visit the Website), mobile analytics software and pixel tags (transparent graphic images, sometimes called web beacons or tracking beacons, placed on a web page or in an email, which indicates that a page or email has been viewed). We do this to analyze trends, track user movement around the Website, gather demographic information, and to generally collect information that we may find insightful or helpful. We, or our third-party service providers, may place cookies or similar files on your device for security purposes, and to facilitate Website navigation. A pixel tag may tell your browser to get content from another server.
Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of the Website may not function properly or may be slower if you refuse cookies. If you block or delete cookies, not all tracking that we have described in this Privacy Policy will stop.
We use cookies provided by Google Analytics to collect statistical information about the use of the Website. We use Google Analytics to learn more about the types of users that visit the Website, their activities on the Website, and to help improve the Website. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google analytics, here: https://tools.google.com/dlpage/gaoptout (requires you to install a browser add-on).
Certain web browsers may provide an option by which you may request your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals”. The Website currently does not respond to Do Not Track Signals.
III. HOW WE USE THE INFORMATION WE COLLECT
We may use the Personal Information we collect from you for a variety of purposes, such as to:
- Provide services through the Platform, authenticate your access to the services and provide analytics services;
- Respond to your inquiries, questions and requests;
- Communicate with you about your activities on the Website and, in our discretion, changes to any Smart Wallet policy or notice;
- Operate, improve, maintain, administer and provide the Website and the Platform;
- Manage our business, including performing accounting, auditing, and other internal functions;
- Evaluate and improve our services, conduct research and perform analysis, learn more about our users and customers, and enhance the customer experience, including to better optimize and target our marketing;
- Comply with applicable laws and regulatory requirements, or as requested by government or regulatory authorities;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
- Protect and defend the rights or property of Smart Wallet; and
- For purposes disclosed at the time you provide your Personal Information or otherwise with your consen
Depending on the context, we may rely on one or more of the following legal bases when processing your Personal Information:
- To fulfill a contract with you or to take steps prior to entering into a contract;
- For our legitimate interests (we consider and balance any potential impact on you and your rights under applicable data protection laws);
- To address our legal obligations; and
- With your consent.
IV. HOW WE SHARE INFORMATION
We may also share your Personal Information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:
Third Parties Providing Services On Our Behalf: We may share your Personal Information with third parties that perform functions on our behalf, such as service providers and vendors that host or operate our Website, analyze data, store data on our behalf, or for other data processing. We maintain an updated list of sub-processors, which is available to customers upon request.
Our Affiliates: We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes, such as business partners with whom we jointly offer products or services.
Business Transfers: In the event that Smart Wallet is involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be sold or transferred as part of that transaction.
Legal Disclosure: We may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to our Website or the public.
No Sale of Personal Information: We have not sold your Personal Information to third parties, including during the twelve (12) months prior to the date of this Privacy Policy. We are not selling your Personal Information to any third parties for their own direct marketing purposes. We may share non-Personal Information, such as anonymous information or aggregate data, with third parties.
V. YOUR RIGHTS
You may be entitled to certain rights relating to your Personal Information. For example, you may be able to:
- Request, once per calendar year, certain information regarding our disclosure of your Personal Information to third parties for their own direct marketing purposes.
- Request, twice per calendar year, to know (i) the specific pieces of Personal Information we have collected about you; (ii) the categories of Personal Information we have collected about you; (iii) the categories of sources from which we collected your Personal Information, (iv) our business purpose for collecting your Personal Information; and (v) the categories of third parties with whom we shared your Personal Information.
- Request to delete the Personal Information we have collected about you. We may deny your request under certain circumstances, such as if we need to comply with a legal obligation.
- Request to correct the Personal Information we have collected about you, if you believe that the Personal Information we have collected about you is inaccurate.
- Receive your Personal Information that you have provided to us in a structured, commonly used and machine-readable format and transmit it to other data controllers (data portability).
- Restrict or object to the processing of your Personal Information for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing.
- Lodge a complaint with a supervisory authority in the place of your residence or the location where the issue that is the subject of the complaint occurred.
We will not discriminate against you for exercising any of these rights. If you wish to make a request or to learn more, please reach out to us using the information provided in the “Contact Us” section below.
VI. OPTING-OUT OF COMMUNICATIONS
At any time, you may choose not to receive marketing and promotional communications from us by (i) selecting the unsubscribe link in the communication that we send you or (ii) contacting us using the information provided in the “Contact Us” section below. Please note that even if you opt-out of receiving the foregoing emails, we may still send you a response when you contact us for other reasons related to your use of the Website or Platform.
VII. CHILDREN
The Website is not directed to children under the age of 18. Smart Wallet does not knowingly collect, use or disclose Personal Information from anyone under 18 years of age. If we learn that we have collected Personal Information from a child under 18 years, we will use commercially reasonable efforts to delete that information. If you believe that we might have any such information, please contact us using the information provided in the “Contact Us” section below.
VIII. SECURITY OF YOUR PERSONAL INFORMATION
We use administrative, physical and technical security safeguards to protect the Personal Information that we collect and process. Our security controls are designed to maintain the confidentiality, integrity and availability of your Personal Information and to protect against reasonably anticipated threats. If you believe that your data is no longer secure, please contact us using the information provided in the “Contact Us” section below.
IX. RETENTION OF YOUR PERSONAL INFORMATION
We will retain your Personal Information for such periods of times required or permitted by law or subject to our retention policies as may be in place from time to time. We consider the following in determining such retention periods: the time required to retain Personal Information to fulfill business purposes; maintaining corresponding business records; improving the performance and quality of the Website and Platform; handling your inquiries; whether we reasonably believe this data will be needed for the handling of any litigation; and whether legal and contractual obligations pose any requirements for data retention.
X. THIRD PARTY SITES AND PRODUCTS
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We do not endorse and are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
XI. TRANSFERS OF INFORMATION
Given that we are an international business, our use of your Personal Information necessarily involves the transmission of data across borders. When we transfer data across borders, we do so in accordance with applicable data protection laws. For example, when we transfer data from the European Economic Area to jurisdictions that are not deemed to have an adequate level of data protection, we may use Standard Contractual Clauses. In the absence of an adequacy decision or Standard Contractual Clauses or any other right to transfer your data, we may rely on your consent as the basis for such transfer.
XII. PRIVACY POLICY UPDATES
From time to time, we may update this Privacy Policy. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. By using the Website, the Platform, or by continuing to provide Personal Information to us after these changes are made, you acknowledge and agree to the revised version of the Privacy Policy.
XIII. CONTACT US
If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at Data Protection Office, support@smartinvestsas.com
