Privacy Policy

Introduction

Welcome to Smarterp (“we”, “our”, “us”). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website https://smarterp.me, use our services, or interact with us in any other way.

The aim of this website’s Privacy Policy is to comply with the duty to provide information and transparency as set out in Article 12 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). As well as in cases where the duty to provide information has been fulfilled through basic “first layer” information in accordance with Article 11 of Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights, this privacy policy corresponds to the additional information known as “second layer”, whose required elements are those described in Articles 13 and 14 of Regulation (EU) 2016/679.

Contact details for any matter relating to data protection:
KUNVENO DIGITAL SL.
Calle Principe de Vergara 109 – PLT 2, 28002 Madrid (Madrid), Spain.
Email address for any matter relating to the exercise of data protection rights: dataprivacy@smarterp.me

Information we collect

We may collect and process the following Personal Data: Name, email address, phone number, postal address, wallet address, and other identifiers that you provide to us voluntarily.
We do not collect Usage Data and do not use Cookies or Tracking Technologies.

The meaning of Personal Data

‘Personal data’ means any information relating to an identified or identifiable natural person. This means any person who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. an IP address – if it can be used to identify the person) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

In short, this includes data that, either by itself or with other data in our possession or available to us, can be used to identify you.

Processing of Personal Data

‘Processing’ means any operation or set of operations performed on your personal data. Smarterp sets out below the detailed information on the processing operation in accordance with the guidelines established by the Spanish Data Protection Agency.

How we use your information

We use the personal data we collect for communication and marketing processing whose purpose is to maintain business relations with customers, future customers, current or potential suppliers and anyone interested in the activities and products of Smarterp. Among the activities of this processing may be requests to receive newsletters, collecting data from a form to manage requests for information on Smarterp products or activities, sending commercial communications via email and any other activity considered to be within the scope of marketing and communication. In accordance with Spanish Law on Information Society Services, you may unsubscribe from commercial communications at any time without this affecting the validity of your personal data in the systems.

a. Data category: identifiers such as first name and last name(s); contact details such as email address, phone number, work address and job title or position.

b. Legal basis: Legitimate interest based on the marketing activities in which the data subject has shown an interest (art. 6.1.f GDPR) by requesting information via the website contact form; or by giving consent to receive newsletters and emails (art. 6.1.a GDPR).

c. Data validity period: The data remain valid for the duration of the business relationship and provided that the data subject does not withdraw their consent or request the erasure of their data. Outdated or obsolete data will be erased as soon as this circumstance is detected.

Sharing your information

We may share your personal data with third parties under the following circumstances:

With service providers: Third parties that provide us services and that help us to operate our business. For example, sometimes a third party may have access to your personal data in order to support our information technology or handle mail on our behalf. We have concluded appropriate data processor agreements with these third parties. Our legal advisers and other professional advisers and auditors.
For legal reasons: As and when necessary to meet a legal requirement, for the administration of justice, to protect vital interests, to protect the security or integrity of our databases or this website, to take precautions against legal liability. Regulatory authorities, courts and administrative bodies, in order to meet legal and administrative obligations, such as tax or labour obligations, for example.
With your consent: We may share your information with your consent or at your direction.

Security of your information

We strive to use appropriate technical and physical security measures to protect the personal data transmitted, stored or otherwise processed from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access thereto, in relation to our website. These measures include IT safeguards and protected files and facilities. Our service providers are also carefully selected and must use suitable protective measures. Industry-standard SSL encryption is used on the website to protect data transmissions. The majority of current browsers accept the level of security necessary to use these areas. However, no method of transmission over the internet, or method of electronic storage, is 100% secure, and we cannot guarantee its absolute security.

Your data protection rights

If you are a resident of the European Economic Area (EEA), you have the following data protection rights under the General Data Protection Regulation (GDPR):

Obtain information as to whether or not Smarterp is processing personal data that concern you.
Request access to your personal data, which means knowing which of your personal data we have.
Rectification, including the right to request that we correct inaccurate personal data.
Request restriction of data processing that concerns you or to object to the processing of your personal data.
Request erasure of your personal data when they are no longer necessary in relation to the purposes for which they were collected.
Object to the processing of your personal data unless you have given your prior consent and unless we demonstrate compelling legal grounds for the processing or for the defence of possible legal claims.
Data portability, which includes receiving your personal data in a commonly used and machine-readable format in certain circumstances, provided that the processing is carried out by automated means.
Withdraw your consent to any processing to which you previously gave that consent.

Please note that your ability to exercise some of these rights may be restricted in the event of legal or other limitations that Smarterp must justify in responding to your request. You may apply to exercise your rights by writing to the email address provided for this purpose or by making an enquiry about your rights using the contact channels identified in the introduction.

In order to process your application, it will be necessary to check your identity and verify that you are the data subject, so your email or enquiry should include your first name, last name(s), national identification number, the specific application request, and the address where you wish to be notified of the response. If necessary, we may ask you for a copy of the document certifying your identity.

If you wish, we can send you a suitable form that will help you complete your application in accordance with Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights.

If your application were disregarded, you may contact the corresponding supervisory authority, the Spanish Data Protection Agency, whose website is www.aepd.es/en and postal address is Calle Jorge Juan 6, 28001 Madrid, Spain.

Links

The Smarterp website may include hyperlinks to other websites that are not operated or controlled by Smarterp . Therefore, Smarterp neither guarantees nor assumes liability for the legality, reliability, usefulness, accuracy and timeliness of the content of such websites or their privacy practices. Before supplying your personal information to such websites, please be aware that their data protection compliance may differ from ours.

Updates and changes to this Privacy Policy

The text of this privacy policy was updated in June 2024.

Smarterp may amend its Privacy Policy without prior notice in accordance with the applicable laws in force at any given time and in keeping with any changes that may occur in its privacy management system.

Settlement of disputes: arbitration clause

The parties agree that all disputes or disagreements deriving from these conditions of use shall be definitively resolved before the Chamber of Commerce, Industry, Services and Navigation of Santa Cruz de Tenerife (Spain), to which the administration of the arbitration and the designation of the arbiter is entrusted, in accordance with its articles and regulations.

Data owner

Global Marketing and Sales Strategy Department
Calle Principe de Vergara 109 – PLT 2, 28002 Madrid (Madrid), Spain.
dataprivacy@smarterp.me