Privacy Policy 

1. WHAT TYPE OF PERSONAL INFORMATION WE COLLECT:

a. Information About You that You Share with Us Directly: When you use our Services, you may give us personal information directly (for example, details you register with us when setting up your account), and we will store that personal information on our systems and process it for the purposes described in this Privacy Policy. Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:

• first name and/or surname
• your email
• your location
• your phone number
• information related to any purchases you make in our Services
• personal information you provide when you ask for help from our customer support team, or when contacting us through our website www.smart81.io, including the content of that communication with our team
• “Identifiers” – information which we treat as your personal information as it relates to you and your use of our Services but is not directly provided by you from your device (e.g. IP address, device manufacturer and model, OS platform)

b. Information You Generate Using Our Services: Transaction activity and history on the Services. When you use our Services, we will collect personal information about the ways in which you use and interact with our Services.

c. Payment Information: We’ll collect information related to any purchases you make. We do not share your financial information, but the payment processors may share non-financial information with us related to your purchases, like your name, billing address, and the services purchased.

d. Cookies and Other Automated Information Collection: We’ll collect information about your device and how you use our Services, including through the use of cookies and similar technologies. We use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s) for advertising purposes and to analyze your experience. We, our service providers, and our business partners use these cookies and other similar technologies to process information, including:

• IP address;
• the type of mobile device you are using;
• platform type (like Apple iOS or Android);
• your operating system version;
• what your current progress is in our Services and the date and time of activity.

Analytics: Smart81.io analyses traffic and other end user activity to improve the user experience. Smart81 and its service providers and business partners may use web server log files and tracking technologies to collect and analyse certain types of technical information, such as cookies, IP addresses, device type, and usage information, including time spent on particular pages. These cookies help us to understand the effectiveness of our Services, and/or marketing campaigns. Our analytics partners include without limitation the following third parties. Please follow the links below for further information concerning the privacy policies and opt-out choices offered by these third parties.

• Google Analytics: https://support.google.com/analytics/answer/6004245?hl=en

e. Other Sources: We may collect information from other third-party sources. We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help improve our Services.

2. WHY WE PROCESS YOUR INFORMATION AND OUR LEGAL GROUNDS:

The main reason we process your personal information is to provide you with the Services and to improve your experience, but there are other reasons as well. We process your information for the purposes below:

• Set up your account and to provide our Services (e.g. process your transaction requests; etc.);
• Identify and authenticate your access to certain features of the Services;
• Improve, optimize and personalize our Services and our users’ experiences;
• Communicate with you about the Services you are using or we think you will like, including new Services;
• Customer service, including technical support;
• Protect the safety and well-being of customers;
• Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale of all or part of our assets;
• For security purposes and to prevent fraud or potentially illegal activities;
• Cooperate with public authorities and law enforcement where lawfully permitted or required;
• Protect Smart81’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties.

Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:

• Establish and perform our agreement with you to provide you the Services
• For our or our partners’ legitimate interests
• Consent (where applicable)
• Compliance with a legal obligation
• Protect your vital interests or those of another person

If you have questions, need further information or want to withdraw your consent please see the CONTACT US section below.

3. HOW WE SHARE INFORMATION:

The main reason we process your personal information is to provide you with the Services and to improve your experience, but there are other reasons as well. We process your information for the purposes below:

a. Our Group Companies: We’ll share your information with other companies in the Smart81 group. We may share your personal information within the Smart81 group companies to enable the Smart81 group to carry out the purposes set out in this Privacy Policy.

b. Third Party Advertising including analytics: We may share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. We do not directly share personal information that identifies you with third-party advertisers for their advertising purposes unless you give us your consent, where legally required. To enable advertisers, advertising intermediaries to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:

• performance data (like the number of clicks on an advertisement);
• certain device information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);

In addition to serving you with relevant ads, the information collected may be used to:

• measure how effective advertising campaigns are;
• offer you targeted advertising in third party services for products and services that are more likely to appeal to you;
• undertake web analytics to analyse traffic and other player activity; and/or
• improve our Services.

Advertisers or advertising intermediaries may collect this information through the use of cookies and other similar tracking technologies. Please note, after clicking on a third-party advertisement or offer, you may no longer be on an app controlled by us. If you do not want to receive tailored in-application advertisements, please see the Section below entitled YOUR RIGHTS. Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies and privacy practices. If you have any questions about how these third-party services use your information, you should review their policies and contact them directly.

c. Safety, Security and Compliance with Law: We’ll share your information if necessary for safety, security, or compliance with legal obligations. Your information, and the contents of all of your online communications, transactions when using our Services and between you and Smart81 may be accessed and monitored as needed to provide our Services and may be disclosed:

• to satisfy any applicable legal obligations;
• when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
• when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
• to protect the rights or property of Smart81 or applicable third parties.

d. Third Party Service Providers: We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services and that support us with our business. We will share your information with third-parties who assist us in delivering and optimizing our Services or perform services on our behalf, like payment processing, analytics, hosting services.

e. Sale or Merger: We may share your information with a third party in connection with a business transition, like a merger or acquisition. Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, we may disclose or transfer your information, including personal information, to the purchaser.

4. YOUR RIGHTS:

Depending on what privacy laws apply to you, you and/or your legal representative have certain legal rights in connection with your personal information. Your privacy rights are explained below.
Subject to certain exemptions, you have the right to:

• Request a copy of your personal information (known as ‘accessing your data’).
• Delete your information. When you ask us to delete your personal information please remember that there may be lawful limitations on this right. For example, we will keep certain payment records or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.
• Correct or update your personal information where it is inaccurate. You can also write to us to make these corrections at contact@smart81.io
• Withdraw your consent by CONTACTING US. Withdrawing your consent will not affect the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.
• Ask us to restrict processing of your personal information or request portability of your personal information.
• Complain to a data protection authority. A list of privacy authorities is available here.
• Manage personal information we receive from third parties’ applications/platforms and from your mobile device: To manage the information we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by those third-party applications and devices.

Opt-Out of Third Party Behavioral Advertising: You can opt out of third-party behavioural advertising in your device and by using other third-party opt-out tools. If you are interested in more information about behavioural advertising and your choices to prevent behavioural web and mobile web advertising from third parties, you may visit the following websites: Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page; and Your Online Choices website. These third-party opt-outs are browser and device-specific and will not apply to your use of our Services through other browsers or devices. All of the opt-out tools described here are provided by third parties, not by Smart81. Smart81 does not control or operate these tools or the choices that advertisers and others provide through these tools.

5. HOW WE STORE AND SAFEGUARD YOUR PERSONAL INFORMATION:

We work hard to protect your information but you also have a role to play. We implement reasonable and appropriate security measures to help protect the security of your information and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information. It is important that you protect and maintain your Smart81 account’s security and that you immediately tell us of any unauthorized use of your account. While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Services. Any transmission is at your own risk.

6. INTERNATIONAL OPERATIONS AND TRANSFERS:

When you use our Services, your personal information may be processed in the Socialist Republic of Vietnam and other countries. As part of our international operations, we may transfer personal information to our group companies, business partners and service providers located internationally for our legitimate business purpose. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident. When we transfer your personal information internationally we treat your personal information securely.

7. HOW LONG WE KEEP YOUR INFORMATION:

We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights. How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for to provide you with the Services or for our legal requirements. We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

8. WE DO NOT SELL PERSONAL INFORMATION:

We do not sell personal information that we collect directly from you. We do allow third parties to collect information relating to your use of our mobile apps through the use of cookies and similar technologies. You can disable cookies through your web browser or opt out of certain types of cookie-based sharing as described in Section 4 above.

9. OUR POLICIES REGARDING CHILDREN:

We seek to ensure that we do not collect information from children. Our Services are not marketed to, or intended for, children. Children are not permitted to use these Services, and we do not knowingly collect any personal information from children. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

10. CHANGES TO OUR PRIVACY POLICY:

We’ll let you know about any material changes to the Privacy Policy. We may update our Privacy Policy from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify. We encourage you to periodically check this Privacy Policy for updates.

11. CONTACT US:

You can contact us with your questions, comments, or concerns. If you have any questions, comments, or concerns regarding our Privacy Policy and/or privacy practices, please send an email to contact@smart81.io