Last update: January 16th 2020
And the legal entity that acts under the applicable laws and regulations as the Data Processor, and in that capacity is responsible for the processing of (personal) data:
Smart Solutions ehf (Company id 680995-2499) Vsk id 81978, Iceland (“we”, “us”, “our”)
We promise to implement the highest standards of privacy and data protection when we design our products and services, offering them to you. For us, the following three key principles play a central role in our privacy and data protection policies:
If you visit our website and use our services, you acknowledge and agree that we store, collect and use your (personal) data in an automated way. We take all appropriate and necessary security measures in order to prevent unauthorized access to, disclosure or modification of all the data we collect and process, and we follow certain organizational procedures to adhere to all privacy and data protection laws that may apply.
If you have any doubts or questions about our privacy and data protection policies, or if you want to exercise your legal rights, please email us at: firstname.lastname@example.org.
2. Your Privacy
All information requested by us is obligatory in order to use our services, and your refusal or failure to provide your (personal) data could hinder your access to our services. We may indicate that some specific (personal) data may not be necessary to provide in order to use our services. If you have questions about which personal data we collect, and is mandatory to provide, please request more information at: email@example.com.
We represent and warrant that we use industry standards to protect your (personal) data. However, you are aware that there is no method of electronic storage that is absolutely safe, and 100% secure on the internet.
As part of our business practice, we may authorize and appoint third-parties, including but not limited to (technical) service and hosting providers, mail carriers, agents and contractors that handle your (personal) data. Upon request, we will provide the most recent list of all the above-mentioned third-parties.
3. Collection and Use
We collect and process different types of information and (personal) data necessary in order to provide and improve our services to you:
|Device Brand and Make||Contact full name|
|Contact email||Company name|
|Contact phone number||Company ID number|
|Company invoice email||Credit card token|
We solely collect and process specific information and (personal) data, when:
Your (personal) data shall be stored for as long as the legitimate purpose requires it, typically for six (6) months. However, there are circumstances under which we retain (personal) data for a longer period of time, for example when you have not withdrawn your consent or in case of a legal obligation or judicial order. Once the retention period expires, we may delete your (personal) data permanently, and as a result your right to access, erase and amend your (personal) data cannot be exercised.
Usage Data and Device Data
Usage data we collect may include the date and time you logged in, app features you used, searches, click path and pages you visited. In addition we may collect Device data, which may include IP and MAC address, type of device and ID, specific apps settings, app crash reports, browser type and version, language settings, and your geolocation based on Bluetooth, Wi-Fi information and GPS.
4. Our Responsibility
We, our employees, agents, and affiliates are fully responsible for your personal information. We may also use the services of third-parties and may share your (personal) data with them.Some of these third-parties may be located outside Iceland, namely in the United States or the European Economic Area. In that case, the transfer of (personal) data to these third-parties will only be done after we have evaluated and fully assessed their privacy policies and they are in accordance with the highest standards of personal data protection and all necessary legal safeguards.
Under no circumstances, persons under the age of thirteen (13) may use our Services or visit our Website according to the US Children's Online Privacy Protection Act 1998 (COPPA). Our services are restricted to Users who are eighteen (18) years of age or older, or an adult according to the applicable law. We do not allow Users under the age of eighteen (18) on our website and platform and we do not collect and process personal information from anyone under the age of eighteen (18). If you suspect a User is under the age of thirteen (13) or eighteen (18), please report this immediately to us.
You may exercise certain rights. You have the right to:
5. Why we process your data
Here we explain the exact reasons and purposes why we process your data:
6. Third-party controllers and processors
Third-Party Service Providers
|Google Analytics (Google LLC)||Visitor’s/User’s data and analytics||USA||https://policies.google.com/privacy?hl=en-US|
|Apple Pay (In-App Purchase) (Apple Payments Inc)||Subscribed User’s data and analytics||USA||https://support.apple.com/en-us/HT203027|
|Google Pay (Google LLC)||Payment data processing||USA||https://support.apple.com/en-us/HT203027|
|Valitor hf.||Payment data processing||Iceland||https://www.valitor.com/about-us/privacy-notice/|
|Borgun hf||Payment data processing||Iceland||https://www.borgun.com/library/Files/L ogfraedi/Borgun%C2%B4s%20Privacy%20Policy.pdf|
9. Legal Information