Please read this Privacy Policy (the "Policy") carefully as it contains important information regarding how, when, and why SmartReach AI LLC collects, uses, and stores your personal data, with whom it may share it, and your rights as a data subject — in connection with the SmartReach AI LLC website, platform, products and services.
Accessing and/or using the SmartReach AI LLC website, platform, products, and services imposes the obligation to comply with the Terms and Conditions.
The website https://www.smartreachai.com (the "Website") and the platform https://app.smartreachai.com/login (the "Platform") are owned and managed by SmartReach AI LLC, a limited liability company incorporated under the laws of the State of Wyoming, USA.
1. Applicability
This Policy applies to the processing activities performed by SmartReach AI LLC and shall be complemented with the Terms and Conditions and the Cookie Policy.
The Website may contain information about or links to other websites outside SmartReach AI LLC's custody and/or control. Carefully read each of their privacy policies when browsing them.
2. Definitions
The terms used within this Policy have the same meanings as those mentioned in the Terms and Conditions, unless otherwise specified:
- "SmartReach AI", "we", "us" or "our" — SmartReach AI LLC and any of its affiliates providing the Website, Platform, products and services.
- "Users" — any natural person or any customer's employees, representatives, consultants, contractors or agents using the Services for the customer's benefit.
- "You" or "your" — a current or potential customer of SmartReach AI, as a User of the Website, Platform, products and Services.
- "Services" — all of our web-based websites, applications, tools and platforms (including this website) provided by us, whether for a fee or free of charge.
- "Personal data" — any information relating to an identified or identifiable natural person.
- "Processing" — any operation performed on personal data (collection, recording, organization, storage, retrieval, use, disclosure, restriction, erasure, etc.).
- "Controller" — the entity which determines the purposes and means of processing personal data. For this Policy, SmartReach AI acts as Controller.
- "Data subject" — an identified or identifiable natural person.
- "Consent" — any freely given, specific, informed and unambiguous indication of the data subject's wishes signifying agreement to processing.
3. Collecting Personal Data
In general, the personal data we process is collected directly from you. However, there may be situations where your personal data is collected indirectly from social media, the website of the company you represent, your employer as a contact person, a third party who recommended you, or various public platforms.
Where we do not receive your personal data directly from you, we will inform you within the legal term.
If you provide us with personal data belonging to other individuals (e.g., colleagues), you are responsible for obtaining their prior approval.
4. Children and Special Data
Our Website and Services are not directed at children. We do not knowingly collect personal data from children. If you believe your child has provided us with personal data, please contact us to request erasure.
We do not collect special categories of personal data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, data concerning health or sex life or sexual orientation, or data relating to criminal convictions, except where expressly regulated by law.
5. Processed Personal Data, Purposes, Legal Grounds and Retention Periods
Below you'll find the purposes for which we process your personal data, the categories of personal data we collect, the legal grounds, and the retention periods.
Where the lawful basis is consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
5.1. Answering requests and providing support
Categories: name, company name, phone number (with country code), email address, time slots, time zone, and any other personal data you choose to include. For scheduled video calls we also process your voice and image; calls are not recorded or stored.
Legal basis: our legitimate interest to communicate with you and provide support.
Retention: for as long as we have a contractual relationship; deleted within 6 months of termination. If no contract exists, stored for 6 months and then deleted.
5.2. Collecting feedback through satisfaction surveys
Categories: name, company name, position/role, LinkedIn profile, and any personal data contained in the review.
Legal basis: your freely expressed consent (withdrawable at any time).
Retention: until withdrawal of consent or until the data is no longer relevant for the purpose.
5.3. Posting your review on the Website
Categories: name, company name, position/role, LinkedIn profile, and review content.
Legal basis: your freely expressed consent (withdrawable at any time).
Retention: until withdrawal of consent or until no longer relevant for the purpose.
5.4. Initiating or carrying out the contractual relationship
Categories: name, company name, company address, position/role, signature (for representatives), phone, email.
Legal basis: our legitimate interest to conclude the Agreement, or performance of the contract if you purchase as an individual.
Retention: for as long as there is an Agreement with you or the company you represent.
5.5. Ensuring functionality and security of the Website and Platform
Categories: name, email, IP address, log files, browser name/version, OS version, device identification, system language, network location data (country/state), website version, interaction data (sections visited, clicks, scrolls).
Legal basis: our legitimate interest to protect personal data and monitor/improve information security.
Retention: generally 3 years, after which data is deleted.
5.6. Marketing and information about our services
Categories: first name, last name, role, employer/represented entity, email, LinkedIn profile, city, country, education, email statistics.
Legal basis: your freely expressed consent or our legitimate interest.
Retention: until you withdraw consent or object. You can unsubscribe via the link at the bottom of any of our emails.
5.7. Providing access to the Platform by creating an account
Categories: first name, last name, email, LinkedIn ID. For paid plans we also process purchase and order history.
Legal basis: our legitimate interest to conclude the Agreement and provide services, or performance of the contract.
Retention: for as long as you are a registered Platform user.
5.8. Providing new prospects and enriching data for our clients
Categories: first name, last name, role, employer, email, LinkedIn profile, city, country, education, email statistics.
Legal basis: your freely expressed consent or our legitimate interest to store your professional contact details.
Retention: until you withdraw consent or object.
5.9. Selecting and recruiting for vacant roles
Categories: first name, last name, phone, email, education, professional experience, targeted role, qualifications, professional and social skills, and any other information you provide.
Legal basis: taking steps at the request of the data subject prior to entering into a contract.
Retention: during the recruitment process. Unsuccessful candidates' data is kept up to 6 months after termination of recruitment.
5.10. Contacting the candidate about new opportunities
Categories: same as 5.9.
Legal basis: your consent (withdrawable at any time).
Retention: up to 2 years from the termination of the selection process or from the date you voluntarily provided your CV.
5.11. Carrying out and enabling your participation in webinars
Categories: first name, last name, email, practice name, role in practice, industry type.
Legal basis: performance of the contract represented by the Terms & Conditions.
Retention: 1 month from the date of the webinar.
In addition to the purposes above, we may process your personal data to fulfill legal obligations and to exercise or defend a right or legitimate interest in judicial, administrative or similar procedures. At the end of the retention periods, personal data will be deleted or anonymized.
6. Tracking Technologies
Our website uses cookies, plug-ins and other online identifiers (collectively "cookies") to ensure functional browsing, provide a better experience, perform statistical analysis, and provide custom content and advertising. Detailed information can be found in our Cookie Policy.
7. Automated Decision Making, Including Profiling
We do not make decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
8. Disclosure and Transfer of Personal Data
We may transfer your personal data, to the extent necessary, to the following categories of recipients: companies from the same group, service partners, subcontractors, payment providers, courier service providers, archiving companies, IT service providers, software or hardware vendors, market research companies, marketing companies, public authorities, courts or arbitral tribunals, and competent criminal investigation authorities.
Where personal data is transferred to third countries, we apply the technical and organizational measures required by law and inform you in accordance with legal requirements.
9. Security of Personal Data
We maintain a variety of appropriate technical and organizational measures to protect your personal data from loss, misuse, and unauthorized access or disclosure. We limit access to those who reasonably need it. We implement physical, technical and procedural safeguards including limiting access, encryption, anonymization, and secure storage.
You should also take measures to protect your personal data — check the sources of information, avoid suspicious links, change passwords regularly, and use appropriate anti-virus and anti-malware solutions.
10. Your Rights and How to Exercise Them
- Right to be informed regarding the processing of your personal data.
- Right of access to confirm whether we process your personal data and obtain the specifics.
- Right to rectification of inaccurate or incomplete personal data.
- Right to erasure when legal requirements are met.
- Right to restriction of processing where applicable.
- Right to data portability to receive your data in a structured, machine-readable format.
- Right to object in certain situations such as processing based on legitimate interest.
- Right to object to commercial communication.
- Right not to be subject to decisions based solely on automated processing, including profiling.
- Right to opt out of sale or sharing of personal data for cross-context behavioral advertising.
- Right to address the Supervisory Authority. For the EU, see edpb.europa.eu/about-edpb/about-edpb/members_en.
- Consent withdrawal at any time without affecting prior lawful processing.
- Right to no retaliation for exercising your rights.
You can exercise your legal rights by contacting our Data Protection Officer at privacy@ssc-digital.com.
We will respond within one month of receiving the request. This period may be extended by two months where necessary; we will inform you within one month of any extension. If we do not take action, we will inform you of the reasons and you may lodge a complaint with the competent Supervisory Authority or take legal action.
11. European Union Representative
In accordance with GDPR (Regulation (EU) 2016/679), our designated representative in the European Union is Mr. Alexandru Ganea. If you are based in the EU, you may contact our representative by email at eurep@ssc-digital.com.
12. Updates
This Policy is subject to periodic review and updates. Please regularly consult this Policy to keep up to date with changes. Any major changes will be notified accordingly.
13. Contact
If you have any questions or concerns regarding the processing of your personal data, or you wish to exercise any of your rights, contact our Data Protection Officer by email at privacy@ssc-digital.com.