We respect the privacy of people who visit not4shy.com. We are devoted to the protection of your personal data. In particular, we are committed to processing your personal data responsibly in compliance with applicable data protection laws and only for defined below purposes.

This Privacy Policy is a legally binding agreement between you ("you" or "your") and incorporated as a legal entity Smart OS Global Inc., registered under the laws of USA and our registered office is at 8 The Green, Suite B, Dover, DE 19901; our registered company number is 93-4169163 (the “Company”, "we", "us" or "our").

The Privacy Policy applies to any processing activities by the Company resulting from your use of the Services, as defined in our Terms and Conditions.

The processing activities shall cover the use, collection, retention, storage, security, disclosure, transfer, disposal, and any other processing of personal data, defined by the applicable laws.

Сapitalized terms used in this Privacy Policy and not otherwise defined shall have the meanings provided for those terms in our Terms and Conditions

Before you give us your consent on the collection and processing of your personal data, or provide us with your personal data, we kindly ask you to read carefully this Privacy Policy. It explains when, where, and why we collect personal data of our users, how we use such data, the conditions under which we may disclose it to others, your rights in respect of your personal data, and how we keep it secure.

With this Privacy Policy, we tried to provide you with clear, plain and complete explanation of privacy matters within the Company. We hope you will have no doubts that your data is safe with us. In case you have any questions about your privacy, - do not hesitate to write us at [email protected]. We will be happy to provide you with needed assistance.

Occasionally, at our sole discretion, we may change this Privacy Policy, so we will kindly ask you to regularly check this page to ensure that you are aware of any changes. We will be posting such changes on this page and update the Privacy Policy modification date at the top of this page. In case of significant changes to this Privacy Policy, we would inform you separately of the relevant changes.

For more details regarding the scope of personal data processed and other relevant purposes, we have prepared separate sections in this Privacy Policy, as indicated below.

Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to the person that collects and processes such information to identify you as an individual. This can be your name, your identification number, your location data, information related to your physical, physiological, genetic, mental, economic, cultural or social life or any other information that may identify you.

Processing of the data means any action performed with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means etc.

Please note that we may process your personal data not only based on your consent, but also when one of the following is applicable:

• processing is necessary for the purposes of the Company legitimate interests on the conditions prescribed by the data protection legislation. In particular, it is necessary to run the Website and to provide the Services, as defined in our Terms and Conditions;

• processing is necessary for the compliance with our legal obligations;

• processing is necessary to protect your vital interests or vital interests of another natural person;

• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

In all cases, we will notify you about applied legal basis for processing and other relevant details per your request.

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

Information you give us:  you provide us with information about yourself if you sign up for an account on our Website, make purchases on our Website, complete any online forms (such as registration forms, competitions, and surveys).

Depending on what you provide, this information can include your name, phone number and email address, date of birth, gender, images, any other User Content you upload to complete your profile and financial information.

We do not intentionally collect, share or process your sensitive personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs etc.). If, as part of a survey, you are asked by us to fill out sensitive data in the questionnaire, then this is completely at your discretion and this data will have separate security of storage.

 Information we receive from other accounts or sources:   we can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, our partners, social media providers, advertising networks and analytics partners, and payment service providers. The specific types of information that we may obtain depends on your settings for that account or website, and will be subject to their privacy policies. We may combine such personal data with the personal data you provided to us.

We supplement the data you provide to us with data from data append services such as public or social graph data in order to better serve you with content. We will append this data to our existing account information to better understand your interests and to provide more relevant recommendations and advertising, to increase your security when using our Website and to comply with our legal obligations, such as sanctions laws. This information can be associated with your personal information such as name, email, address, physical address or phone number.

 Information our IT systems collect about you:   each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes: cookies and device information.

 Cookies.   The cookies are tiny pieces of code that remains in your computer after you have visited some website. These pieces then enable the server to provide you with the information that is customized with your needs when you use some platform or website for the next time. By giving your consent to the Company for use cookies you make our website more efficient, fast, and safe, you improve its functioning. Nevertheless, you may block, delete, or disable saving cookies on your device if your web-browser allows to do this. You can read more on our Cookies Policy.

 Server log files.   Some data are collected automatically to run the Website, including browser type and browser version, operating system, referrer URL, host name of the accessing computer, and the time of the server request. We presume that these data cannot be personal, because the combination of these data is impossible. However, we reserve the right to check these data in retrospect in the case of proved illegal use.

 Usage data.   In order to improve and optimize the work of our website, in order to understand your needs and provide services that are relevant to you, we may collect your Usage Data. Usage Data reflect your behavior on our Website: use our services, download documents from us, personal information in application forms on the Website, subscribe for alerts or newsletters, attend one of our events, or an event hosted at our premises, make a request/complaint, visit to our Website, including your browsing experience, for example which pages you have viewed and for how long. We may collect such data only if you give us a consent to do so. You provide us with your consent by means of: clicking “OK” on Cookie Policy Notification and/or filling your personal data in the application forms on the Website. We collect Usage Data with the help of third-party services which include but are not limited to Google Analytics and Google AdWords.

 Push Notifications.   If you are a registered user of the Services, you may receive notifications if you allow us to send them to you on your PC, or other device and in the settings of the browser you are using, such as: technical and administrative notifications concerning the Services; notifications from the other users, messages and other service features; advertising and marketing notifications. At any time, you can manage your push notification preferences or deactivate these notifications at any time by turning off the notification settings on the PC or other device you use or in the browser settings of your device.

If we decide to change the purposes of processing specified above, we will notify you of such changes before using your personal data for the new purposes through the update of this Privacy Policy.

Please, note that we may compile and publish some statistic information showing the number of registration, visits, purchases, requests or complaints we receive or other information. Such statistics will be totally anonymous.

If you do not want to provide us with the requested personal data for the purposes specified above, you may not have the access to certain Services, defined in the Terms and Conditions. Limited use of the Website is always possible without providing your personal data to us.

Information We Use	How & Why We may use the data provided	When does this become critical?
Email	Create a username and log in. To contact you if necessary regarding any Service issues, news, changes etc. Customer service may use this to verify your identity and assist you. Fraud detection and prevention against you or for verification purposes.	When you sign up to the service. Each time you log in.
Your Full Name	Display the information on your profile. Customer service may use this to verify your identity and assist you. To contact you if there is an issue. Fraud detection and prevention against you or us.	When other users identify you.
Phone number	Verify your identity. Fraud detection and prevention against you or us.	When we need to verify your identity.
User Content uploaded to your account	Display the information on your profile. Offer you better services and ads. Customer service may use this to verify your identity and assist you. To contact you if there is an issue. Fraud detection and prevention against you or us.	When other users identify you. When we enhance our Services.
Purchase details and history	Provide you the purchased services. For our user service team to verify your identity and assist you with your orders. Train our user service team For accounts and regulation reasons.	When you make a purchase, we will need to record this data for future actions relating to user service and accountancy.
Billing address	To verify the authorized use of the credit or debit card. Customer service may use this to verify your identity and assist you. Fraud detection and prevention against you or for verification purposes.	When you make a purchase, we will need to record this data for future actions relating to user service and accountancy.
Credit card information	We do not keep a record of your credit card information; we use a secure 3rd-party service to process your payment for your order on our Service.	When you make an order, so payment providers can process your payment.
Anonymous Aggregate data	To create internal reports, test our IT systems, research, data analysis, improving our Website, building & developing our Website or developing new products or services. We only use and share this information with third parties when it is anonymous i.e. without identifying information.	We use anonymous aggregated data at all times on our service.

 

We may also process your personal data for communicating with you about our Services, and promotions, including newsletters, new product offerings, special discounts, event notifications, and special third-party offers. Therefore the aforementioned list of personal data and purposes of its use is not exhaustive.

In order to provide high-quality services, we hire people, enters into agreements with private entrepreneurs and partners, also cooperates with other services providers, companies and organizations. For these reasons, some of your personal data can be passed on to the persons mentioned above.

First of all, our employees may have access to your data. Then, we may transfer your data to our sub-contractors and affiliates. We secure such transmission by including standard contractual clauses adopted by the European Commission and compliant with the data protection laws into our data processing agreements. When providing us your personal data you agree to such transfer and processing within the purposes set in this Privacy Policy.

To do this, we may share your information with these third parties in the following circumstances:

• Third party service providers for business purposes:  to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:

• Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. Currently we use the following payment providers [please, insert the name and location of the payment provider].  Our payment providers may be changed from time to time so you have to monitor such changes on your payment page. In case of processing your payment information by the payment provider you should be governed by the privacy policy and the cookie policy of such payment provider.

• Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information in order to check for any fraudulent behavior. In case of processing information in order to check for any fraudulent behavior by the anti-fraud and credit check provider, you should be governed by the privacy policy and the cookie policy of such anti-fraud and credit check providers. You acknowledge that our anti-fraud and credit check providers may be changed from time to time.

 • Marketing Tools providers and analytics and search engine providers,  like Google (company name Google LLC, their privacy policy is accessible at  Google's Privacy Policy), that we use to assist us in the improvement and optimization of the website. 
 Google Analytics.  With the use of Google Analytics, we collect such data as IP-Address, your device model, screen resolution and operation system, session durations, your location. Basing on these data, we analyze your needs and interests, evaluate effectiveness of our campaigns and improve our Website to make its content relevant to you and the Website itself – available for smooth viewing with your device. As well as we use this data for advertising campaign. 
 Google AdWords (Google Ads).  Google AdWords allows us to better understand how our users interact with our advertisements and to tailor these advertisements to you. 
For more information please read the privacy policy of Google accessible at  Google's Privacy Policy.

• In case of processing your information by such marketing tools providers or analytics and search engine providers, you shall be governed by their privacy policy and cookie policy. You acknowledge that our marketing tools providers or analytics and search engine providers may be changed from time to time. We will update information concerning such providers used by us, but we are not responsible if this information is not up to date.

 • Performance Marketing and Recommendations Providers  hat help us deliver advertising and recommendations of the products tailored to your interests and needs.

 • Research companies  that we can engage to help us carry out surveys regarding your use of our Website and Services.

 • Advertisers for marketing purposes:  we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our and our partners’ services to you and others;

 • Third party service providers to enrich data:  We may also enrich, match or combine information we hold about you with data from other sources, for instance by sharing some of your personal data with selected business partners. We do this to better understand your user profile and interests so that we can deliver customized offers and other personalized service

 • Third parties where we are considering a corporate transaction:  we are always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganizations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred;

 • Sentry  Sentry helps us to track our Website performance and displays the impact of errors across multiple systems. For more information on how Sentry processes collected personal data please read its privacy policy accessible at Sentry's Privacy Policy

 • SendGrid.  SendGrid provides us with email automation, signup forms, and list management. For more information on how SendGrid processes collected personal data please read its privacy policy accessible at SendGrid's Privacy Policy

 •To comply with legal requests:  on occasion, we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and

 • Aggregated information with third parties:  we may aggregate your information with the information of other users, creating a dataset of information about the usage of our Website, registrations and other general, grouped information about our users on the basis of our legitimate interest to understand the usage and demand for our services. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, other providers to allow them to better stock products, and our investors.

Your personal data will be stored and processed in the European Economic Area (“EEA“). Any personal data gathered by Company in connection with our services may also be transferred to, processed, and stored outside the EEA in countries where data protection laws may be less protective than the legislation where you live. This may happen when facilities belonging to the Company or one of our service providers are located in a country outside of the European Economic Area or in a country which is not the party to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981). 
Supplying the Company with the personal data, you permit its transfer outside the EEA within the bounds of such use. When a transfer to non-European countries happens, we ensure that it takes place in accordance with this Privacy Policy and applicable laws. 
The Company will take maximum effort to maintain appropriate safeguards for protecting the personal data you provide against unlawful or unauthorized, accidental destruction, alteration, access, disclosure, loss or use. However, the security of information transmitted through the Internet cannot be guaranteed, and you assume some risk regarding the security of any information you submit through any website, including this one.

In all cases when we transfer your personal data to other persons, we are confident that your personal data is protected and used only for the purposes specified in this Privacy Policy. We achieve such safety by using only certified services and products, signing agreements on protection of personal data with contractors and partners, as well as taking technical measures to ensure the data is protected when stored and used, and also while being processed and transferred.

You also have to be aware of the fact that we may disclose your personal data to enforce and comply with the law. In other words, we may disclose information necessary for the investigation or legal process on official request or the official bodies acting within their powers.

Please, note that our Website may contain the links to other platforms and websites. This Privacy Policy does not cover the collection and processing of data from the moment when you follow such links. You will be governed by the conditions of the privacy policies of those platforms and websites. Thus, we encourage you to read that privacy policies carefully.

There are three reasons where we may share your data with third-parties that we have not listed here:

• Professional Advisers and Investors:  We may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims, and/or as part of our relationship and obligations to our investor organizations. This is in our legitimate interests.

• Group:  It is possible we could sell our business to a third party or re-organize our business or become insolvent. In that scenario, our database of users is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business.

• Law Enforcement/Legal Compliance:  We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security. We may also use your data and share it with the recipients listed in this Privacy Policy for the purpose of complying with our legal obligations.

Part of the role of the Company is to market the Services to enable more people to use them. To do so we use a number of different third-parties to help us with these initiatives. We see these anonymized transfers of data as critical to the running and future success of our business and you cannot opt-out of them if you use our Services.

In addition to the anonymized data we send to the third-parties, we may ask permission from you to use extended data to help give you a better service. A better service may include (but is not limited to):

• the ability for us to personalize our email communication to you based on identifiable information;

 • the ability for us to send push notifications to you;

 • the ability for us to place advertisements on the third-party websites based on your browsing or purchasing history with us;

 • whilst browsing the Website, having us push relevant deals and information to you based on your specific interactions with the website.

For this we will ask you to opt-in to our marketing initiatives; you will automatically be opted-in of these services when you join the Website. If at any stage, you would like to opt in or out you can do so in your account settings.

To provide you the Services and the Website, including to allow you to administer your account and to optimize your experience we need to use the information that we collect in a number of different ways.

We use the information for marketing and advertising purposes. Where you have told us, you would like to receive marketing communications or when you have signed up for our Services, we will use your personal information (including your name and email address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing user information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out instructions in the promotional emails that are sent to you.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our website or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for services available on the Website. For information about opting out of targeted advertising and controlling the use of cookies, please see the Cookies Policy.

Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.

• To register and manage your account in our Website, we collect your name, email, password and other additional details you may wish to add in your account, like phone number, gender, interests and beliefs etc. The legal basis is the performance of a contract with you.

• To fulfill the purchases, you make through our website, we collect your name, billing information, phone number, purchase details. The legal basis is the performance of a contract with you.

• To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV we do not store them and only transfer them to our authorized payment providers. The legal basis is the performance of a contract with you.

• To provide you with our user services (including helping you to solve any issue you have with our Services, updating you about any change to our terms of service, or contacting you to know how was your experience with us) we collect your name, email, password and addresses and your contact history with us (including phone records of our conversations). The legal basis is the performance of a contract with you and our legitimate interests in retaining you as a user.

• To monitor the quality of our user services, we collect your name, email, password and addresses and your contact history with us. The legal basis is the legitimate interests in running our business.

• To administer, maintain and optimize our Website and our Services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.

• To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect the Company and its users from fraudulent activities and compliance with a legal obligation.

• To send you marketing communications and personalized offers, we collect your name, email, phone, number, address, date of birth, purchase history, browsing history and behavior, device information, preferences, cookie identifiers, internal identifiers, country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your consent.

• To carry on research, analysis, enquiries and surveys on your use of our Website, we collect your name, addresses, email, device information. The legal basis is our legitimate interests in running our business and improving our Website and your experience.

• Advertising and retarget advertising of our, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.

• To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improve our Website.

• To manage requests and complaints. When we receive a request or complaint (‘enquiries’) from a person, we create a file containing the details of the enquiry. This normally contains the identity of the requestor or complainant and any other individuals involved in the enquiry. We will use the personal data from your enquiry only in order to process the request or complaint, check on the level of our services and provide you with the comprehensive response. Such data will be processed on the contractual basis as we will use it to provide you with information you have intentionally requested. Without this data we will not be able to consider your issue and give you a response regarding it.

 To us your privacy is our top priority. As part of our commitment to transparency in the way we process your information, we explain here what automated decision-making and profiling are, why it is used at our Service and how you benefit from it. 

 What is automated decision-making and profiling?  
Automated individual decision-making under GDPR states for making a decision about an individual solely by automated means (i.e., using computers and algorithms only, without any human involvement in the decision-making process). 
Profiling states for evaluating certain things about an individual, including interests, preferences or behavior, through an automated processing of personal data (e.g., using computers and algorithms to determine someone’s interests based on his or her online behavior).

 Do we rely on automated decision-making or profiling?  
Automated decision-making and profiling are invisible features that are at the core of the Services you use at our Website, upon which we constantly improve and without which we would be unable to help you find the connections you’re looking for. 
We use the information you and other users provide us (such as your profile), along with information we collect from your use of our Service (like your location, should you allow us to collect it), to power our best-in-class matching algorithm and recommend the most compatible people to you, based on a number of criteria, including the attributes you told us (or we noticed) you like, common interests and location. We use information about you to show you useful and relevant ads on and off our Service and measure the effectiveness of these ads. We also use information about you to deliver offers and discounts tailored to your profile. We use automated decision-making and profiling as part of our moderation efforts, as well as to promote the safety and security of our users by making it easier to prevent illegal and unauthorized actions from happening and to swiftly and efficiently detect and fight those actions when they happen. 
This processing may have a significant impact on users found to be carrying out illegal or unauthorized activities, including suspension and account closure, without prejudice to other legal actions we could take.

We store personal data in case we consider you to be potentially interested in our Services or you are already our client. Your personal data will be stored by us no longer than is necessary for the purposes for which the personal data are processed. Thus, retention period depends on the purpose of processing and may be specified per your request.

We also store the personal data of subjects who agreed to the subscription to our newsletters. The data is stored until a subscriber asks to be unsubscribed in the respective email form.

After the expiration of retention period, we shall terminate the processing of your personal data or pseudonymize such data, unless stated otherwise under applicable laws.

To provide our Website and our Services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of the European Economic Area (“EEA”), mostly to one of our partners or to one of the third parties with which we work with.

We transfer the personal information to one of our partners or to one of the third parties with which we work with, outside the EEA, to the extent such transfer is needed to properly provide the services to you.

Personal data collected by us may be transferred to, and stored and processed in any country in which we or our affiliates or processors maintain facilities. We have put in place reasonable safeguards to ensure the protection of any personal data transferred from the EEA to the United States and other countries. By using the Services, you consent to your personal data being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy and our Cookie Policy. We may only transfer your personal data if appropriate safeguards have been implemented and on the condition that enforceable data subject rights and effective legal remedies for data subjects are available.

Under the data protection laws, you have rights we need to make you aware of. The rights available to you depend on the legal basis for processing of your personal data:

Right to access to your personal data and right to data portability	You have the right to request us an access to your personal data and to know the source of these personal data. You may request to be provided with your personal data in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information.
Right to be informed	You have the right to ask the Company to provide information about what personal data concerning you is being processed and the basis for such processing.
Right to request a rectification of your personal data	You have the right to request rectification of inaccurate personal data or request that incomplete data be completed.
Right to request an erasure of personal data	You have the right to request us an erasure of your personal data if its processing is no longer needed in relation to the purposes for which they were collected, and also if there are no legitimate grounds for the processing.
Right to restrict the processing of your personal data	You have the right to request a restriction of processing of your personal data if you dispute the accuracy of your data, or we no longer need these data for processing purposes and if you are against the processing of the data.
Right to withdraw your consent	You have the right to withdraw your consent for the collection and processing of your personal data at any time by contacting us. After your request, we will process such request in a timely manner and we will no longer process your personal data unless stated otherwise under applicable laws.
Right to object to the processing of your personal data	You have the right to object to processing of your personal data on the basis of legitimate interest or as part of a task in the public interest or for an official authority; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms. However, in some specific cases, the public interest may prevail and we may be allowed to continue using your personal data.
The right to object to automated processing	You have the right to object to a decision based on automated processing.
The right to be forgotten	You have the right to request the erasure of your personal data.
Right to lodge a complaint	You have the right to lodge a complaint directly with us at [email protected] or with the competent data protection authority in the case you consider our processing of your personal data as non-compliant with the applicable data protection laws.

If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.

Please, note that when processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification. We will no longer process your data for such direct marketing purposes. You may refer relevant sections of this Privacy Policy to learn whether we process your data for direct marketing purposes. You have the right to opt-out of marketing emails and other direct marketing (if any).

Any requests to exercise your rights can be directed to us through the contact details provided below. These requests are free of charge.

Our Website may contain links to other services and websites. When you use a link online to visit a third-party website, you will be subject to that website’s privacy policy, cookie policy and terms and conditions, which may differ from ours. We strongly recommend you to review the privacy policy or other rules of usage of these websites.

We will provide information about the actions taken on your request without undue delay after receiving the request. This period may be extended by two further months if we consider it necessary, considering the complexity and number of the requests. We will notify you about such renewal within one month of the receipt of the request together with the reasons for such delay.

We process your data by using computers and/or other IT enabled tools. We take both technical and organizational measures to ensure that your personal data are processed in a manner that provides appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. For example, our Website uses SSL encryption for security reasons and in order to protect the transmission of sensitive content, such as the requests you send to us.

We use verified contractors, with whom we sign data processing agreements, who might have access to your personal data. We also guide and train our personnel to process your data securely and in accordance with our internal data protection policies.

We use only secure places of storage, such as provided its own or rent servers located in Dublin [AWS - Cloud Server Services]

Our Website is intended for adult use only. We do not knowingly collect data from minors under the age of majority in their country of residence and its Website does not target such minors. We encourage parents and legal guardians to take an active role in their children’s online activities as well as their interests and ask the minors not to submit any personal data to us. If you become aware that we have collected personal data from children under the age of majority in their country of residence, please notify us about it.

If any of your personal data is stolen, lost or illegally accessed - known as a personal data breach - we would inform you as well as the respective data protection agencies as to such accidents without undue delay. We would also inform you directly if there are serious risks related to your personal data or privacy due to the personal data breach. We will do our best to minimize any possible risks related to personal data breach.

We hope this Privacy Policy helped you to understand how we process your personal data at the Company. If you have any questions or comments with regard to this Privacy Policy, please do not hesitate to contact us at [email protected]

Smart OS Global Inc.

8 The Green, Suite B, Dover, DE 19901

Company number: 93-4169163

Contact us:
+1 650-797-0046

 [email protected]