Privacy Policy

Thank you for visiting our website and for your interest in our company and services. Data protection and data security are very important to us. For your further visits to our website, we would like to inform you about data collection, processing, and use when visiting, registering, and using our service. As well as objection, revocation and other rights to which you are entitled as a person affected by data collection and use.

This we do in compliance with the applicable data protection legislation and have committed to a vast selection of Privacy Laws from across the globe based on our customer base. In particular, we adhere to the;

• New York State “Stop Hacks and Improve Electronic Data Security Act” (SHIELD Act)

• EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework published by the US Department of Commerce

• Federal Trade Commission FIPs

• Department of Homeland Security FIPPS at Work

• California Consumer Privacy Act,

• EU General Data Protection Regulation (GDPR)

A/B Smartly is the Controller of your personal data.

This Data Protection Policy describes how we handle and protect your personal data and the choices available to you regarding the collection, process, access, and how to update, correct, and delete your personal data. Additional information on our personal data practices can be found in our Terms and Conditions. This Data Protection Policy is intended for you as a user of our website.

What is personal data?

Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).

What data do we collect?

We may collect data or ask you to provide certain data when you use our website and services. The sources from which we collect Personal Data are:

Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”) and may include direct identifiers such as name, address, email address, and phone number.

Data collected online or through indirect identifiers such as login account number, login password, payment details, or IP address.

Data collected that is linked, for example, if you have used our service and later choose us again, we will link your data and treat that linked data as Personal Data.

We organize collected Personal Data as Account Data and Billing Data.

Account Data is everything we need to set up your account and includes your email address and username, and information connected with our services, such as license keys, your First and Last Name, your Business address, and phone number.

Billing data is everything we need to set up your payment including your name, email address, masked credit card number, and in certain circumstances, your billing address and your phone number if this is not already collected.

As described above, we link data and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out the service contracted for.

Like every other website, we use cookies. You can find out how cookies work here. You can learn about what cookies are here. And we will tell you what cookies we are using in our Cookies Policy.

On what grounds do we use Personal Data?

We use your Personal Data for the following purposes and on the following grounds:

On the basis of fulfilling our contract (when you buy our service)

On the basis of your consent (when you subscribe to our newsletter)

On the basis of legal obligations (for obligations such as tax, accounting, anti-money laundering, or when a court or other authority asks us to)

On the basis of our legitimate interest (for communications about security, privacy, and performance improvements of our services. Or for establishing, exercising, or defending our legal rights.)

Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

When do we disclose your Personal Data?

We disclose your Personal Data in response to your business inquiry or your request for information within our Company in order to provide the best service possible and within our legitimate interest.

We may share your information with organizations that help us provide the services described in this Data Protection Policy and who may process such data on our behalf and in accordance with this Data Protection Policy, to support this website and our services. For example, with our legal other professional advisors.

We may also share information with our secure payment gateway provider, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorize payment following a secure link. The information which you supply in such cases is not within our control and is subject to the payment gateway provider’s own Privacy Notice and Terms and Conditions.

In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimization of our website which is subject to our Cookies Policy.

We may disclose personal information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation, or regulatory authority asks us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our rights, property, or personal safety of our staff, the website, and its users.

We will only keep the information required to provide our service as long as you are a client. So that we can meet our contractual obligations and for a period after that to identify issues, respect claim limitation periods, and resolve any legal proceedings.

We are a global business that provides its products and services all around the world. In order to reach all of our users and provide all of them with our software, we operate on an infrastructure that spans the globe. The servers that are part of this infrastructure may therefore be located in a country different to the one where you live. In some instances, these may be countries outside of the European Economic Area. Regardless, we provide the same level of protection to all Personal Data it processes and rigorously apply the GDPR principles across our Company.

At the same time, when we transfer Personal Data outside of the EEA, we always make sure to have appropriate and suitable safeguards. For example, standardized contracts that are approved by the European Commission and specific documents that legally bind the receiving party to adhere to a high level of data privacy and data protection. As well as encryption and several algorithms such as Blowfish, Triple DES, and RSA encryption.

You can learn how long your information is held and when it is destroyed from our Data Retention Policy which you can request using our contact form.

Your Rights

You have the right to:

• information about the processing of your personal data

• obtain access to the personal data held about you

• ask for incorrect, inaccurate, or incomplete personal data to be corrected

• request that personal data be erased when it’s no longer needed or if processing it is unlawful

• object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation

• request the restriction of the processing of your personal data in specific cases

• receive your personal data in a machine-readable format and send it to another controller (‘data portability’)

• request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision

Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.

How do we protect your Personal Data?

We protect your data using state-of-the-art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards, and procedures to ensure the highest level of administrative protection.

In more detail to access our database, the user must be authorized, is challenged through a two-way authentication system, and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting-edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorized personnel must have a legitimate need to know interest such as being your point of contact or service your user account.

The data we collect from you may be stored, with appropriate technical and organizational security measures applied to it, on our servers in the USA. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.

To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us using our contact form.

California Privacy Rights

Sources and Categories of collected personal information

you can find all sources and categories of collected personal information above

Business or commercial purpose for collecting information

you can find all purposes of processing personal information above

Categories of third parties with whom the business shares personal information

you can find all categories of recipients of personal information listed above

Changes

This Data Protection Policy and our commitment to protecting the privacy of your personal data can result in changes to this Data Protection Policy. Please regularly review this Data Protection Policy to keep up to date with any changes.

Queries and Complaints

Any comments or queries on this policy should be directed to us using the following contact details.

A/B Smartly Keizersgracht 520 H 1017EK Amsterdam The Netherlands privacy@absmartly.com