Last Updated: 21 Oct 2020
What Information Do We Collect?
How We Use Your Information
Sharing of Your Information
- a) subscribers and Users information: In general, information you enter on the Site is available to the other persons – whether they are customers, subscribers, staff members or others – to whom you give access to your account or to whom you give access to the information through the normal operation of the Site.
- b) payment information: We use credit card and other personally identifiable information (such as PayPal email addresses) you submit to us on the Site, and other information that we collect, as required, to process payments you make through the Site through our payment processor intermediaries. We do not store credit card or other payment method information unless the User choose to enter credit card information for use in the SmartPablo recurring profiles module; in all other cases our payment processors have the sole and complete responsibility for the storage of credit card and payment information. We may also share personally identifiable information with our payment processor intermediaries for risk management and fraud prevention.
- c) legal requests and business transitions, emergencies: In certain situations, SmartPablo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. SmartPablo may disclose your personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, (c) as otherwise required or permitted under any applicable law, rule, or regulation, and (d) in good faith, to protect or defend the rights or property of SmartPablo and other users and (e) if SmartPablo is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. When providing the Service, we are assisted by certain third-party – subprocessors: Google Inc. (Business Analytics Services), Amazon Web Services, Inc. (Cloud Service Provider). A subprocessor is a third party data processor engaged by SmartPablo, who has or potentially will have access to or process Service Data (which may contain Personal Data).
Other Information Collectors
Consent for Withdrawal
You can withdraw the consent you have given for marketing purposes by clicking the appropriate link provided in every email newsletter. If you withdraw your consent, we will immediately cease processing the relevant personal data and delete it, unless there is another legal basis for continued processing thereof. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.Contact us at legal@SmartPablo.com) to initiate the steps required. We will verify your information prior to processing and proceed with the steps necessary within the applicable laws and regulations. Correcting, Updating, and Transferring Your Personal Information Upon written request SmartPablo will provide you with information about what personal information we have about you. To review, delete, and update your personal information to ensure it is accurate, you may login into your account to make the changes, or you may contact us at legal@SmartPablo.com. We will respond to your request within a reasonable timeframe. We may ask you for further information from you to help us respond to your request.
Your rights under GDPR
Listed below are your rights and options in relation to personal data that we process. If you want to use any of these options, please contact us at legal@SmartPablo.com.
- a) right of access to personal data (art. 15 GDPR) - you may request that we confirm whether or not we process your personal data and, if we do, you have the right of access to this data (a copy of your personal data) and information about the terms of processing it. We will generally provide this information within one month of the date of your request,
- b) right to rectification and completion of the data (art. 16 GDPR) - you may at any time rectify, complete and update your personal data in your account on the Settings → Company Profile page. We recommend that you do so every time this data changes. If you have a problem updating your personal data, please contact us.
- c) right to erasure (art. 17 GDPR) - In addition to withdrawal of consent, you may have your personal data erased where one of the following grounds applies: (i) the personal data is no longer necessary for the purposes referred to above, (ii) you object to your personal data being processed on the legal ground of a legitimate interest and there are no overriding legitimate grounds for the processing or you object to your personal data processing for direct marketing purposes, (iii) the personal data has been unlawfully processed, or (iv) the personal data has to be erased for compliance with a legal obligation, where the processing is not necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims, unless the GDPR grants other exemptions,
- d) right to restriction of processing (art. 18 GDPR) - In addition, you may request restriction of processing of your personal data, if (i) you contest the accuracy of your personal data, for a period during which its accuracy is being verified, (ii) personal data has been processed unlawfully (instead of requesting erasure of the data), or (iii) we no longer need the personal data for the purposes referred to above, but you need it for the establishment, exercise or defence of legal claims, (iv) you object to your personal data being processed on the legal grounds of a legitimate interest, for a period during which it is being verified whether there are legitimate grounds for continued processing thereof,
- e) right to portability (art. 20 GDPR) - you have the right to have personal data, which you have provided to us for the purposes of performing the contract or on the grounds of your consent and which we process using automated means, transferred to another organization, if technically possible,
- f) right to object (art. 21 GDPR) - you may object, for reasons related to your particular situation, to your personal data being processed on the legal grounds of a legitimate interest. In the event of such objection, we will cease processing your personal data unless compelling legitimate grounds for continued processing or for the establishment, exercise or defense of legal claims are demonstrated,
- g) right to lodge a complaint - if you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office for Personal Data Protection, residing at Hraničná 12, 820 07 Bratislava, Slovak Republic (dataprotection.gov.sk).
SmartPablo is a complex business network that connects millions of users. This network relies on the exchange and sharing of information that is important to others in your network. The complexity and connected nature of the system requires that this history exists in perpetuity to accommodate proper function and accounting for the other systems that you have connected to via contracting hours, invoices, estimates. SmartPablo will reasonably assure that information will be deleted in a compliant manner. When a customer chooses to close an account we will remove your information from our marketing and billing systems. This will ensure that there are not further mailings or billings directed towards the cancelled user.
International Transfer of Personal Information
We do not share your personal information with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which SmartPablo has operations. Therefore, your personal information may be processed outside of the EEA and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers. We have implemented safeguards to ensure an adequate level of data protection where your personal information is transferred to countries outside the EEA. For further details on the transfer of your personal information, including a list of the organizations with whom said information may be shared, please reach out to our team at legal@SmartPablo.com.
It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email our data protection representatives at legal@SmartPablo.com.