Privacy Policy

Last Updated: 23 September 2025

Please read this Privacy Policy (hereinafter referred to as the “Policy”) carefully as it contains important information regarding how, when, and why SSC International Ltd collects, uses, and stores your personal data, with whom it may share it, as well as to inform you about your rights as a data subject and the measures taken to protect your personal data, in connection with SSC International Ltd’s processing over its website, platform, products and services. 

Accessing and/or using SSC International Ltd website, platform, products, and services by any person imposes the obligation to comply with the provisions set forth in the Terms and Conditions.

The website https://www.smartreachai.com (hereinafter referred to as the “Website”) and the platform https://app.smartreachai.com/login (hereinafter referred to as the “Platform”) are owned and managed by SSC International Ltd, a company incorporated by Israel laws, headquartered at Mishol Hateana 3, Karnei Shomron, Israel.

1. APPLICABILITY

This Policy regarding the processing of personal data only applies to the processing activities performed by SSC International Ltd and shall be complemented with the Terms and Conditions and the Cookie Policy. 

The Website may contain information about or links to other websites that are outside SSC International Ltd custody and/or control. Carefully read and review the privacy policies of each of those websites when you browse on them to get an understanding of how your personal data is being used and shared by those third-party websites.

2. DEFINITIONS

The terms used within this Policy have the same meanings as those mentioned in Terms and Conditions, unless otherwise mentioned in this Policy.

•  “SSC”, “we”, “us” or “our” means SSC International Ltd and any of its affiliates that are providing the Website, Platform, products and services.
• “Users” means any natural person or any customer’s employees, representatives, consultants, contractors, or agents who are using the Services for customer’s benefit.
• “You” or “your” means current or potential customer of SSC, as a User of the Website, Platform, products and Services provided by SSC.
• “Services” means all of our web-based websites (including this website), applications, tools and platforms that you have subscribed to or that we otherwise make available to you, and are developed, operated, and maintained by us, accessible via the Website, the Platform or another designated URL, and any ancillary products and services, including any consulting services, that we provide to you either for a fee or free of charge; Services or other products or features made available by us to you on an unpaid trial or free basis are considered free Services.
• “Personal data” means any information relating to an identified or identifiable natural person;
• “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processing activity(ies)” means one or more operations that relate to one of the different stages that the processing of personal data may involve.
• “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, SSC acts as Controller.
• “Data subject” means an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 
• “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the user’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

3. COLLECTING PERSONAL DATA

In general, the personal data we process is collected directly from you, as a data subject. However, there may be situations where your personal data is collected indirectly from social media, from the website of the company you represent, from your employer as a contact person, from a third party who recommended you or from various public platforms (for example ad platforms).

When we, as the Controller, do not receive the personal data directly from you, we will inform you within the legal term about our processing of your personal data.

If you provide us with personal data belonging to other individuals (for example, colleagues), you have the responsibility to make sure you have obtained prior approval from those persons for sharing their data with us.

4. CHILDREN AND SPECIAL DATA

Our Website and Services are not directed at children. We do not knowingly or intentionally collect personal data from children who have not reached the level of maturity in their country and who are not able to assume obligations in accordance with the applicable legislation. 

If you are the holder of parental responsibility of a child who has not reached the level of maturity in the country of residence and you believe your child has provided us with personal data, please contact us to request the erasure of their personal data and we will act upon your request in accordance with the legal requirements. 

We do not collect nor is our intention to collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, or personal data relating to criminal convictions and offences or related security measures, excepting the situations expressively regulated by the law.

5. PROCESSED PERSONAL DATA, PURPOSES, LEGAL GROUNDS AND RETENTION PERIODS

Below you will find information about the purposes for which we process your personal data, the categories of personal data we collect for those purposes, the legal grounds on which we carry out the processing activities and the periods of time we store the personal data in relation to the purposes of the processing.

We will inform you and, where the lawful basis is your consent, we will ask for you freely-given consent if we intend to process your personal data for a new purpose that is materially different from that for which the personal data was initially collected.

You may refuse to provide part or all of your personal data. Certain personal data are essential to fulfill the purposes below and your refusal to provide necessary information may result in our impossibility to deliver the Services requested. 

Where the lawful basis for the processing is the data subject’s consent, you may withdraw your consent at any time without constraint and without affecting the lawfulness of the processing prior to its withdrawal.

Depending on the nature of our relationship or interaction, we will process your personal data for the following purposes:

5.1. Purpose: Answering requests and provide assistance and support related to accessing/using our services to ensure customer satisfaction

Personal data categories: Name, company name, phone number (including country code), email address and any other personal data that you choose to include in the subject and/or description of the request, available time slots within your calendar, time zone.

For those cases where you choose to schedule a video call with us, we will also process your voice and image. These personal data will not be stored, as the video calls are not recorded.  

Legal basis: Processing of your personal data is necessary considering our legitimate interest to communicate with you and provide our support in solving your requests that arise from using/accessing our services, and to maintain and promote your satisfaction.

Retention period: We generally store your personal data for as long as we have an existing contractual relationship in place. Your data will be deleted within 6 (six) months if you choose to terminate the contractual relationship. If we don’t have a contractual relationship yet, but you choose to contact us, we will store your personal data for a period of 6 (six) months after which it will be deleted. 

5.2. Purpose: Collect your feedback through satisfaction surveys in order to help us improve our products and services 

Personal data categories: Name, company name, position/role within the company, LinkedIn profile and any other personal data provided by you and contained in the review message.

Legal basis: Processing of your personal data is necessary considering our legitimate interest to improve our products and services. 

Retention period: Personal data will be stored for 1 (one) year from the date of providing the feedback.

5.3. Purpose: Post your review on the website to build trust and credibility with potential customers and increase sales

Personal data categories: Name, company name, position/role within the company, LinkedIn profile and any other personal data provided by you and contained in the review message.

Legal basis: We rely on your freely expressed consent when you voluntary fill out our review form. You can withdraw your consent at any time, without affecting the legality of the processing based on consent before its withdrawal.

Retention period: Personal data will be stored for as long as we have your consent until withdrawal, in which case data will be deleted. However, we can proceed to the deletion of personal data when we decide that it is no longer relevant for achieving the purpose.

5.4. Purpose: Initiate or carry out the contractual relationship with you or your employer or with the company that you represent

Personal data categories: Name, company name, company address, position/role within the company, signature (for the representatives), contact details such as phone number and e-mail address.

Legal basis: Processing of personal data is performed considering our legitimate interest to conclude the Agreement and provide services to the company that you represent, or the performance of a contract represented by the Agreement concluded with you when you are purchasing the services as an individual.

Retention period: Personal data will be stored for as long as there is an Agreement with you or with the company that you represent.

5.5. Purpose: Ensure functionality and security of our Website and Platform, perform checks and technical support, prevent and identify frauds

Personal data categories: Name, email, IP address and log files.

When using the website, we also collect and process data such as: browser details i.e. name and browser version, the name of the operating system version of the device on which the browser is installed, device identification, system language, your device’s network location data (such as country and state), as well as the version of the website you are using.  

In addition, we collect, and process data related to your interaction with the website, such as the sections visited and the number of clicks and scrolls.  

Legal basis: Processing of your personal data is performed considering our legitimate interest to protect your personal data and to monitor and improve the information security of our products or services. 

Retention period: We generally store your personal data for 3 (three) years, after which your data will be deleted.

5.6. Purpose: Inform you electronically about promotions, offers, or similar promotional activities, and any other information related to our Services that we think you may be interested in (e.g., industry information, new blog posts) to increase sales.

Personal data categories: First name, last name, role, employer/represented entity, contact data (email address), LinkedIn profile, city, country, education, email statistics.

Legal basis: We rely on your freely expressed consent or our legitimate interest if the case, to send you direct marketing and information that we think you may be interested in.

Retention period: Personal data will be processed until you withdraw your consent or object to the processing, after which the data will be deleted where there is no other legal ground for the processing. You can withdraw your consent or object to the processing at any time, by clicking Unsubscribe/Opt-out at the bottom of any of our emails, without affecting the legality of the processing based on the consent or our legitimate interest before withdrawal or objection. 

5.7. Purpose: Provide you access to our Platform by creating an account 

Personal data categories: First name, last name, e-mail, LinkedIn ID. If you choose to sign up for any of our paid plans, we will also collect and process your purchase and order history.

Legal basis: Processing of personal data is performed considering our legitimate interest to conclude the Agreement and provide services to the company that you represent, or the performance of a contract represented by the Agreement concluded with you when you are purchasing the services as an individual.

Retention period: We generally store your personal data for as long as you are a registered user of our Platform. 

5.8. Purpose: Provide new prospects and enrich data for our clients

Personal data categories: First name, last name, role, employer/represented entity, contact data (email address), LinkedIn profile, city, country, education, email statistics.

Legal basis: We rely on your freely expressed consent or our legitimate interest if the case, to store your professional contact details. 

Retention period: Personal data will be processed until you withdraw your consent or object to the processing, after which the data will be deleted where there is no other legal ground for the processing. 

5.9. Purpose: Selecting and recruiting for filling vacant roles

Personal data categories: First name, last name, phone number, e-mail, education, professional experience, targeted role, profession or qualification, professional and social skills and any other relevant information provided by you, as candidate.

Legal basis: Processing of personal data is necessary in order to take steps at the request of the data subject prior to entering into a contract. 

Retention period: Personal data will be processed during the recruitment process. The data of unsuccessful candidates will be kept for up to 6 (six) months from the termination of the selection and recruitment process to handle possible complaints, after which personal data will be deleted. 

5.10. Contacting the candidate (i.e. you) in case of new opportunities and proposing job offers

Personal data categories: First name, last name, phone number, e-mail, education, professional experience, targeted role, profession or qualification, professional and social skills and any other relevant information provided by you, as candidate.

Legal basis: Processing of your personal data is based on your consent. You can withdraw your consent at any time, without affecting the legality of the processing based on consent before its withdrawal.

Retention period: Your personal data will be stored for up to 2 (two) years from the termination of the selection and recruitment process you have previously applied for, or from the date you have voluntary provided your CV to us, as long as we have your consent. At the end of the retention period, personal data will be deleted. If you decide to withdraw your consent, we will proceed to the deletion of your personal data.

5.11. Purpose: Carry out and enable your participation to the webinars you have booked

Personal data categories: First name, last name, e-mail, practice name, role in practice, industry type.

Legal ground: Processing of your personal data is necessary for the performance of the contract represented by the Terms & Conditions. 

Retention period: Personal data will be stored for a period of 1 month from the date of the webinar. 

In addition to the purposes mentioned above, we may process your personal data for the purpose of fulfilling our legal obligations under the laws governing our activity, including those regarding equal opportunities and non-discrimination, ensuring physical and IT security and protecting whistleblowers in the public interest. In these situations, the categories of data processed and the data storage periods are determined according to the applicable legal provisions.

Your data may also be processed, based on the legitimate interest of the Controller, for the purpose of exercising or defending a right or legitimate interest in a judicial, administrative or similar procedure, in which the Controller is involved or to respond to requests from public authorities, courts and tribunals or criminal investigation and prosecution bodies, based on and within the legal obligations the Controller is subject to. The categories of data processed and the storage periods are determined on a case-by-case basis, depending on the applicable legal procedures and provisions.

At the end of the retention periods specified above, personal data will be deleted or anonymized, as applicable to the specific situation.

6. TRACKING TECHNOLOGIES

Our website uses cookies, plug-ins and other online identifiers (collectively referred to as “cookies”) in order to ensure functional browsing or to provide a better browsing experience, to perform statistical analysis regarding accessed information, or to provide you with custom content and advertising appropriate to your preferences and interests.

Detailed information regarding the cookies we use may 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 that this is 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, court or arbitral tribunals, as well as competent authorities to investigate criminal offenses.

Personal data may be disclosed or transferred to the categories of recipients mentioned above in order to provide our Services at the highest quality level, ensure the intervention of specialists by outsourcing parts of our business or to provide access to services and benefits according to our business partnerships, or to ensure compliance with the specific legal obligations to which we are subject according to the activity carried out.

In the event that personal data is transferred to third countries we will apply the technical and organizational measures required by law and we will inform you about the transfer in accordance with the legal requirements.

9.  SECURITY OF PERSONAL DATA

The security of your personal data is important to us. Therefore, 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 personal data to employees or contractors who we believe reasonably need to retrieve that information to provide our Services. Considering the current state of technology, we have implemented reasonable physical, technical and procedural safeguards designed to protect your personal data, such as limiting access, encrypting, anonymizing, or storing it on secure media.

It is very important that you, as a data subject, know the risks and take the measures to protect your personal data, for example by checking the sources of information, avoiding access to suspicious or unknown links, regularly changing passwords and using appropriate anti-virus and anti-malware solutions.

10. YOUR RIGHTS AND HOW TO EXERCISE THEM

The law grants data subjects enforceable and effective rights concerning their personal data which can be exercised under particular conditions.

You have the following rights regarding your personal date: 

• Right to be informed: You have the right to be informed regarding the processing of your personal data, as we are doing through this Policy.
• Right of access: You have the right to obtain confirmation whether or not we process your personal data, as well as information on the specifics of the processing activities, and get access to that personal data.
• Right to rectification: You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• Right to erasure: You have the right to obtain from us without undue delay the erasure of your personal data, to the extent that the legal requirements are met. Personal data will be erased when the legal requirements are met. 
• Right to restriction of processing: If the applicable legal provisions are met, you have the right to obtain the restriction of processing of your personal data.
• Right to data portability: If the applicable legal provisions are met, you have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format, and the right to transmit those data to another Controller.
• Right to object: In certain situations, such as when we process personal data based on legitimate interest, you have the right to object to the processing of your personal data. In the event of unjustified opposition, as Controller we are entitled to further process your personal data.
• Right to object to commercial communication: You may also object to the processing of your personal data for the purpose of sending commercial messages.
• Right not to be subject to decisions based solely on automated processing, including profiling: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on you or affects you similar to a significant extent.
• Right to Opt-Out of Sale or Sharing of Personal Data: If we sell your personal data to third parties or share it with third parties for cross-context behavioral advertising, you have the right, at any time, to stop us from selling or sharing your personal data.
• Right to address to the Supervisory Authority: You have the right to file a complaint with the competent Supervisory Authority on any violation of your rights regarding the processing of your personal data. If you want to contact the Supervisory Authority from your place of residence in EU, you may find the contact details at https://edpb.europa.eu/about-edpb/about-edpb/members_en. 
• Consent withdrawal: To the extent that we process your personal data based on your given consent, you can withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
• Right to No Retaliation: If you choose to exercise any of these rights, we will not discriminate against you in any way. However, if you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services, or we may be unable to execute the employment or collaboration agreement with you.  

Except for the right to contact the Supervisory Authority, which you can exercise using the contact details indicated above, you can exercise your legal rights by contacting our Data Protection Officer by e-mail at privacy@ssc-digital.com.  

We will respond to your requests without undue delay and in any case within one month of receiving the request. This period may be extended by two months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, stating the reasons for the delay.

In the event that we do not take action on your request, we will inform you, without undue delay and no later than one month after the receipt of your request, of the reasons for not taking action. In such a case, you have the possibility to lodge a complaint with the competent Supervisory Authority or to take a legal action.

11. EUROPEAN UNION REPRESENTATIVE

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR), our designated representative in the European Union is Mr. Alexandru Ganea. If you are based in the European Union, you may contact directly our representative by e-mail at eurep@ssc-digital.com.

12. UPDATES

This Policy is subject to periodic reviews and updates to ensure that it always corresponds to reality, and it is in line with the applicable legal requirements. For this reason, please regularly consult this Policy to keep up to date with any changes. Any major changes to this Policy will be notified accordingly.

13. CONTACT

If you have any questions or concerns regarding the processing of your personal data, this Policy or how it applies, or you wish to exercise any of your rights, you can contact our Data Protection Officer as follows:

• Email: privacy@ssc-digital.com