All collection, processing and use (hereafter “usage”) of data by Smartella is exclusively for the purposes of providing the Smartella services (hereafter “services”). The services have been designed with the goal of collecting as little personal data as possible to function. By “personal data”, we mean all particulars related to an identified or identifiable natural person (the “data subject”).
The following statements describe which types of data we collect when you use our services, what happens with this data, and how you can object to this data processing, where applicable.
Data Controller and Owner
For the purposes of the EU General Data Protection Regulation (GDPR) (EU) 2016/679, the responsible entity is:
Name: Amir Shurrab
Smartella LTD.
Company number 11290781
hello@smartella.co.uk
Birmingham, Holt Street,
Birmingham,
England,
B7 4BB
Definitions
“Our Website(s)” and “Smartella Websites” refers to any website owned and/or operated by Smartella (as listed above).
User is the individual using software Smartella, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.
Data we Collect
When you visit our website, our server temporarily saves details of your access in its logs. These logs contain the following data, and are kept until their automatic deletion:
- The IP address of the computer making the request
- The date and time of your request
- The requested URI
- The amount of data transferred to you in response
- Whether the request was successfully processed or not
- Identifying data about the browser and operating system you use
- The referring website from which you made the request
- The name of your Internet Service Provider
The purpose of recording this data is to make it possible to serve the website to you (by establishing a TCP/IP connection), to secure our servers, the technical administration of our infrastructure as well as the optimisation of our services. Only in the case of unauthorised access or attacks on our infrastructure will your IP address be analysed.
No further information is required from you in order to access our website other than that listed above.
Among the types of Personal Data that Smartella collects from User, by itself or through third parties, there are:
- First Name & Last Name
- Phone number
- Address, State, Province/Region, ZIP/Postal code, City, Country
- Password
- Cookie and Usage Data, IP address.
Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when using Smartella.
Any use of Cookies – or of other tracking tools – by Smartella or by the owners of third-party services used by Smartella, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.
Failure to provide certain Personal Data may make it impossible for Smartella to provide its services.
Users are responsible for any Personal Data of third parties obtained, published or shared through Smartella and confirm that they have the third party’s consent to provide the Data to the Owner.
The use of the Data processed by the Service
All Data processed via the analysis conducted by Smartella are used by Smartella only for the purpose of providing the service to the Users. Such data will not be transferred or sold by Smartella to any third party, nor will it be used by the Owner for any purpose connected to Smartella own business. The Owner reserves the right to aggregate the Data imported on the application by the different Smartella Users, for the purpose of creating anonymised aggregated metrics.
Keeping your data secure
In order to secure your data, we have put in place technical and organisational measures which meet the requirements of the GDPR, and require any third-party service providers we use to do the same.
When we use third parties to provide the services, for example, infrastructure service providers, these third parties are only engaged after a comprehensive review.
Your data is only ever saved on secure servers, which may only be accessed by authorised personnel.
Third-Party Service Providers in non-EEA Countries
In order to provide our services, we use third-party services located outside the European Economic Area. Where such transfer occurs, Smartella ensures that such transfer occurs under the necessary legal provisions as required by the applicable legislation in order to provide for an adequate level of protection of Your Personal Data (e.g. adequacy decision of the EU commission (e.g. EU-US Privacy Shield), binding corporate rules, or EU standard contractual clauses)
Use of Cookies
In addition to the previously listed data, cookies will be saved on your computer when you use our website. Cookies are small pieces of textual data which are saved on your hard disk by your web browser, through which Smartella, who sets the cookie’s contents, can collect certain information about you. Cookies cannot execute any code, nor transfer any viruses to your computer. We use them in order to anonymously or pseudonymously analyse the use of the website, and present relevant offers to you.
This website uses the following types of cookies, whose scope and functionality is detailed in the following paragraphs.
– Transient cookies are automatically deleted when you close your browser. They are used particularly as session cookies. These save a so-called “session ID” which is used to link subsequent requests made by your browser to each other. Through this, your computer can be recognised when you return to our website. These session cookies are deleted when you log out or close your browser.
– Persistent cookies are only deleted after a predetermined duration, which can be different for each cookie. You can delete these persistent cookies anytime, though the “Settings” configuration of your browser. We advise you, that if you do so, that not all functionality of this website will be available in some cases.
The placement of cookies on your computer can be prevented through the relevant settings of your internet browser. Previously set cookies can also be deleted through the settings of your browser. We advise you that preventing the placement of cookies on your computer can mean that not all functions of our website are available without limitations.
Website Registration
The data subject can register on the website. For this to take place, it is required that the data subject enter their details in the relevant signup forms. The data given by the data subject to register will solely be used for registration, and not passed to any third parties unless Smartella has a lawful ground to do so. In the course of registration on our website, your IP address, date and time of access will be recorded, in order to prevent any potential misuse. During, or after the registration, the data subject is free to alter their personal data. It is also possible for the data subject to completely cancel their registration so that all personal data is deleted.
Third-party services
Google Analytics
Our website uses Google Analytics. This is a service of Google Inc (hereafter “Google”) which analyses website access, and enables us to improve our site.
The responsible entity is:
Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA, 94043, United States
The analysis of your use of our website is made possible through the use of cookies. Information obtained via these cookies is transferred to Google servers located in the United States, and saved there. The analyses of your actions on our website is transferred to us in the form of reports. Google may give this information to further parties where legally required to do so, or these parties are contracted to by Google. The Google tracking on our website uses the “anonymizeIp()” function, which truncates the transmitted IP addresses so as to prevent the direct identification of any individual users.
You can stop the placement of Google Analytics cookies on your computer through the settings of your web browser. If you do so, we cannot guarantee that all the functions of our website will be fully available to you. You may also stop the placement of cookies through the use of browser extensions, such as:
https://tools.google.com/dlpage/gaoptout
You can find further information about Google’s data processing and data protection at:
https://policies.google.com/
And
https://www.google.com/analytics/terms/
Payment Gateway – Stripe
Smartella uses Stripe to process payments for some of our existing customers and provide billing information to these customers.
The responsible entity is:
Stripe, Inc
185 Berry Street,
Suite 550,
San Francisco, CA 94107
For those existing customers who are billed with Stripe, the following data is sent, and stored by Stripe:
Your name and email address
Details of your payment method (credit card number, expiry date, CVC)
Your IP address, and the time and date of your transaction
Your billing address
Your ability to use Smartella functions are reduced should you not use our integrated Stripe service.
You may find further information about Stripe’s data processing and data protection here:
Jira Support Desk
Smartella uses Jira Support Desk to provide support services to its clients.
The responsible entity is:
Atlassian Corporation Plc
888 Broadway
Floor 4
New York, NY
10003
United States
Your ability to use Smartella functions are reduced should you not use the support desk with Jira.
You may find further information about Jira data processing and data protection here: https://www.atlassian.com/software/opsgenie/privacy
Changes to this Privacy Policy
Smaretella reserves the right to update this Privacy Policy from time to time without notice. Any changes are effective when we post the updated Policy on our website. We recommend that you regularly check back. We may provide you with notices about changes to this Privacy Policy if you are a registered user of Smaretella.
Contact
Should you have further questions, or wish to make contact with us, you can write us an email to hello@smartella.co.uk . When you do so, the data required to answer your query will be automatically saved and processed. Your data will not be transferred to third parties unless Smaretella has a lawful ground to do so.
Deletion of Personal Data
Smaretella only keeps and processes personal data for so long as it is necessary. When the purpose of the data processing has been fulfilled, your personal data will be deleted in accordance with our data retention policy, unless we are legally required to retain it. Data retention policy is available upon request.
Right to Access, Change, or Delete Personal Data
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
Right to Access
Customers have the right to know what personal data about them is included in the databases and to ensure that such personal data is accurate and relevant for the purposes for which Smartella collected it. Customers may review their own personal data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Smartella policies. Upon reasonable request Smartella allows customers access to their personal data, in order to correct or amend such data where inaccurate. Customers may edit their personal data by logging into their account profile or by contacting Smartella by phone or email. In making modifications to their personal data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of personal data, customers should submit a written request to hello@smartella.co.uk
Requests for Personal Data
Smartella will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the personal data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Smartella receives a request for access to his/her personal data from a customer, then, unless otherwise required under law or by contract with such customer, Smartella will refer such Data Subject to the customer.
Satisfying Requests for Access, Modifications, and Corrections
Smartella will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate personal data.
Questions, Complaints, Dispute Resolution
Smartella commits to resolve complaints about our collection or use of your personal information. European Union individuals with enquiries or complaints regarding our Privacy policy should first contact Smartella at: hello@smartella.co.uk . Additionally, you always have the right to make a complaint to the relevant authorities (https://ico.org.uk/) regarding our processing of your personal data.
How you can exercise your rights
Should you wish to exercise any of these rights, you will need to provide proof of identification that you are the person to whom the data relates. The data you will receive includes data we have related to you, the source of that data, the recipients, or types of recipients to whom the data was transferred, and the purposes for which the data was stored. To exercise these rights, please contact our support at hello@smartella.co.uk .
Our responsibilities as a Data Processor
As a technical services provider who stores the personal information of EU citizens on behalf of Data Controllers, we have certain responsibilities under GDPR which we comply with, including:
Managing Data Processing – Smartella has clear documentation on where our data comes from, how it is stored, and where it goes after we get it. Smartella will only process personal data on instructions from the controller, and inform the controller if it believes said instruction infringes on the GDPR (28.3)
Accountability and Governance – Smartella takes extraordinary steps to secure your data, ensure stability and uptime, manage data backup and disaster recovery, and regularly test security (32.1)
Authorized Use of Sub-Processors – Smartella uses subprocessors as a routine part of offering our service. It is our responsibility to ensure our subcontractors comply with GDPR, and we will comply with those rules. As a Data Controller, your agreement to our use of sub-processors is part of our legal Terms of Service and required to be an Smartella user. We maintain a list of sub-processors which can be provided upon request.
