Last Updated March 23rd, 2023

Privacy Policy

The privacy of visitors to our website www.Smart Convo.com (the "Site") and the security of their personal information are of utmost importance to Smart Convo. ("Smart Convo," "we," or "us").


The categories of personal information we gather and store on the Site, as well as how we use and disclose personal information, are all thoroughly covered in our Privacy Policy document. In the context of this privacy statement, "personal information" refers to any data that can reasonably be used to directly or indirectly identify, describe, relate to, or be associated with an individual or, where appropriate, a household. Only personal data acquired about our customers and personal data gathered on the Site are covered by this privacy policy (as defined below). This Privacy Policy does not apply to any information collected offline or via channels other than this Site or in connection with providing our Services (as defined below).


1. COLLECTING INFORMATION

HOW WE COLLECT PERSONAL INFORMATION:

What personal information we collect depends largely on the interaction that takes place between you and Smart Convo, most of which can be categorized under the following:

Using Smart Convo Software as a Service. We retain all the content you give when you use any Smart Convo Software as a Service (the "Services"), including but not limited to team member accounts generated, files, photographs, project information, and any other information you provide to the Services.

We also gather information about how the Services are used within and through the Services. This could refer to things like user counts, traffic patterns, broadcasts, etc.

Using the Site: We gather specific data from you when you use the site, which is further defined below. This data, alone or in combination with other data, may constitute personal information.

Types of Personal Information:

(i) Smart Convo Customers (“Customers”): Name, address, business name, identification, information from social media profiles that are accessible to the general public, email, IT data (IP addresses, use data, cookie data, browser data), and financial data (credit card details, account details, payment information). Your credit card transactions are handled by a third-party service provider on our behalf. These third parties are bound by their individual contracts.

(ii) Purchasing a subscription. We collect information when you sign up for a Subscription for the Services in order to process your payment and create your customer account. Name, email address, physical address, phone number, and, if applicable, firm name are all included in this data. To enable you to recognize the credit card used for future purchases, we keep the last four digits of your credit card on file. Your credit card transactions are handled by a third-party service provider on our behalf. These third parties are bound by their individual contracts.

(iii) Customer-generated content. Our products and services frequently allow you to contribute feedback, such as suggestions, compliments, or problems encountered. You are welcome to offer this input as well as take part in the discussion on our blog and community page by leaving comments. Your user name, city, and any other information you choose to include in your remark will be made public if you choose to do so. The privacy of any information you choose to publish to the website, including in our blogs, is at your own risk. The same goes for the veracity of any material posted there. Any information you reveal becomes public knowledge. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law or your personal privacy.

(iv) Data collected for and by our Customers. You may import personal information you have obtained from your users, customers, prospective customers, social network and messaging platform contacts (collectively "Subscribers") or other individuals into our system as you use our Services. You are in charge of ensuring that you have the required authorization and legal justification for us to collect and process information about your Subscribers and anyone else as we have no direct interaction with them. We may utilize and incorporate information you've given us, that you've given us, or that we've gathered about Subscribers into features as part of our Services.

(v) Information collected automatically. Our systems may automatically record certain information about how you use our site, including both customers and casual users (we refer to this information as "Log Data"). Log Data may contain details about a user's Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our site they visited and how long they spent there, how frequently they use the site, search terms, the links they clicked on or used on our site, and other statistics.

When you use our Services, Smart Convo and our partners may use a variety of technologies to collect and store information, including cookies and other tracking technologies on our website like pixels and web beacons. The use of cookies can be managed by users at the browser level. Log files and cookie data can both be used alone or in conjunction with other data to create personal information.

(vi) Sensitive personal information. Subject to the provisions in the next paragraph, we request that you not communicate or reveal to us any sensitive personal information (e.g., social security numbers, information on racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic traits, criminal background, or union membership) via the Services or otherwise.

You must give us your agreement to handle and use any sensitive personal information you communicate or reveal to us in accordance with this Privacy Policy. An example of this would be when you upload user-generated content to the Site. You must not supply such sensitive personal information if you do not agree to its processing and use by us. You can exercise your data protection rights to stop, limit, or delete the processing of this sensitive personal information. Your data protection rights and choices, which are described below under the heading "Your Data Protection Rights & Choices," allow you to object to, restrict, or erase the processing of this sensitive personal information.

  1. PURPOSE OF DATA COLLECTION

For service operations (i) To run, keep up, manage, and enhance the Services; I to process payments you make through the Services; (ii) to better understand your needs and interests and personalize your experience with the Services; (iii) to manage and communicate with you regarding your Services account, if you have one; (iii) to send you information about the Services by email; (iv) to process payments you make through the Services; and (iv) to process payments you make through the Services.


To communicate with you. If you request information from us, register for the Services, or take part in our surveys, contests, or events, we may send you Smart Convo-related marketing communications if permitted by law, but you will have the option to opt out.

Administration and analysis: We utilize automatically gathered information to run the Service and the Site, and we analyze (and may hire third parties to analyze) this information to develop and enhance the Site and the Services by expanding their features and functionality and adapting it to our Users' requirements and preferences.

To analyze trends, operate the website, track users' online activities, deliver adverts that are relevant to them, and compile demographic data about all of our users.

To comply with law. In order to comply with applicable laws, legitimate demands from government agencies, and other legal processes, such as to react to subpoenas, we utilize your personal information as we deem necessary or appropriate.

With your consent. We may use or share your personal information with your permission, such as when you agree to allow us to post your testimonials or endorsements on our Site, advise us to take a certain action with regard to your personal information, or opt into third-party marketing communications.

To create de-identified data for analytics. We may anonymize personal data. By removing information that enables you to be personally recognized from the data, we de-identify personal information. We then utilize the de-identified data for our legitimate business needs.

For compliance, fraud prevention and safety. In order to (a) enforce the terms and conditions governing the Services, (b) protect our rights, privacy, safety, or property, and/or that of you or others, and (c) protect against fraudulent, harmful, unauthorized, unethical, or illegal activity, we use your personal information as we deem necessary or appropriate.

To provide, support, and improve the Services we offer. This includes how we make use of the information our customers give us so they can use the services to interact with subscribers. This includes, for instance, compiling data from your use of the Services or visit to our Site and disclosing it to third parties in order to enhance our Services. In order to deliver and support our Services or to make certain Services features available to you, this may also involve disclosing to third parties your information or the information you supply us about your Subscribers.When we do need to share personal information with third parties, we take precautions to protect your data by requiring them to sign a contract with us stipulating that they will only use the personal information we transfer to them for legitimate business purposes in accordance with this Privacy Policy.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

With the exception of the circumstances outlined in this privacy statement, we never disclose or sell the personal information you give us to other companies without your express approval. We may divulge personal data to third parties in the following situations:

  • Service Providers. We may work with outside firms and personnel to manage and provide Services on our behalf (such as bill and credit card payment processing, customer support, hosting, email delivery and database management services). According to the terms of the agreement(s) we have in place with these service providers, these third parties are only allowed to use the personal information about you to carry out these duties for legitimate business objectives.

  • Professional Advisors. We may share your personal information to professional advisors such as lawyers, bankers, auditors, and insurers as needed in the course of the professional services that they provide to us.

  • Business Transfers. We may sell or acquire businesses or assets as our company grows. Personal information may be included in the transferred assets in the case of a corporate sale, merger, reorganization, dissolution, or other similar event. You understand and accept that your personal information and other information may continue to be used in accordance with the terms of this Privacy Policy by any successor to or purchaser of Smart Convo (or its assets). In addition, Smart Convo may share aggregated personal data with prospective buyers or business partners in order to describe our services.

  • Compliance with Laws and Law Enforcement; Protection and Safety. As required by law, Smart Convo may divulge information about you to governmental, law enforcement, or private parties. We may also use this information for other purposes, such as to: (a) comply with subpoenas or other legal process; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety, or property; and/or (e) communicate with you.

4. YOUR DATA PROTECTION RIGHTS & CHOICES

You have the following rights:

  • You can contact us at any time and request access to the personal data that Smart Convo has collected by sending an email to support@Smart Convo.com.

  • By signing into their account, Smart Convo account users can check, update, rectify, or delete the personal information in their registration profile. Owners of Smart Convo accounts can get in touch with us to complete the aforementioned tasks or with any additional requests or inquiries.

  • Residents of the European Economic Area ("EEA") may object to the processing of their personal information, request that processing be limited, or, in cases where it is technically feasible, ask that their personal information be transferred to another party. Again, you can exercise these rights by getting in touch with us through the information provided below.

  • Similarly, if we gathered and processed your personal information when you were a resident of the EEA with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not have any impact on any processing we carried out before it, nor will it have any impact on processing of your personal information carried out in reliance on legal justifications other than consent.

  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the U.S. and Canada) are available here.

In compliance with the relevant data protection regulations, we react to every request we get from people trying to exercise their rights to data protection.

Access to Managed by our Customers.  Smart Convo has no direct relationship with the persons whose personal information is stored within the Custom User Fields handled by our Service. Any person who wishes to have access to, or w

ho would like to update, amend, or delete any personally identifiable information submitted by our users, should contact the Customer.



5. RETENTION OF INFORMATION

We shall store personal information we process on behalf of our Customers for as long as necessary to offer our Services or indefinitely to comply with our legal duties, resolve disputes, prevent abuse, and enforce our agreements. We will remove personal data from our database if forced to do so by law.

6. DATA TRANSFERS

Your private information may be retained and processed wherever we have offices or where we hire service providers. By accepting the terms of this privacy statement, you acknowledge, agree, and consent to (1) the transfer of personal information to and processing of that information on servers located outside of the country in which you reside and (2) our collection and use of that information as described herein and in accordance with the data protection laws of the countries in which we have facilities or where we engage service providers, which may differ and be less protective than those in your country of residence.



7. CHILDREN’S INFORMATION

We think it's critical to offer children online additional protection. We urge parents and guardians to spend time online with their kids in order to watch, engage with, or otherwise supervise and direct their online behavior. The Site and/or the Services are not intended for use by those under the age of 16, and Smart Convo does not knowingly collect or solicit personal information from those under the age of 16 through the Site or the Services. You are not allowed to try to sign up for the Services or provide any personal data to us, such as your name, address, phone number, or email address, if you are under the age of 16.

If it turns out that we unknowingly gathered personal data from a person under the age of 16 without obtaining their consent, we will quickly delete that data. If you are the parent or guardian of a minor and think we may have any details from or about that minor, please get in touch with us.

8. SECURITY

Notice of Breach of Security

 

In the unlikely event that an illegal access into our system has a detrimental impact on you or your Subscribers, Smart Convo will provide you as much advance notice as possible and detail the efforts we took to thwart the attack.

Safeguarding Your Information

Considering the risks inherent in the processing and the nature of the personal information, we take reasonable and adequate steps to secure it from loss, misuse, and unauthorized access, disclosure, modification, and destruction. We make every effort to store the personal data we obtain from you on the Site, through the Services, and in other ways in a secure operating environment that is not accessible to the general public, but we cannot ensure the security of your data while it is in transit or while it is being stored on our systems. Furthermore, even while we make an effort to protect the accuracy and security of personal data, we can't guarantee that our security measures will stop others, such so-called hackers, from gaining unauthorized access to personal data. We make no guarantees or representations regarding the security of your personal data against theft, unauthorized access, or modification by 3rd parties.

Your information is safeguarded both during and after the transaction by our credit card processor's usage of security protocols. You can email us at support@Smart Convo.com with the subject "Queries about privacy statement" if you have any concerns about the protection of your personal information.

9. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION (EEA VISITORS/CUSTOMERS ONLY)

If you reside in the European Economic Area, the nature of the personal information in question and the particular context in which we acquire it will determine the legal basis for our collection and use of such information. Normally, we will only obtain personal information about you when you give us permission, when we need the information to carry out a contract with you, or when processing is necessary for our legitimate business interests. In rare circumstances, we may also be required by law to get personal data from you.

If we ask you to supply personal information in order to comply with a legal requirement or to engage into a contract with you, we will make this apparent at the time and advise you whether the giving of your personal information is required or not (as well as of the possible consequences if you do not provide your personal information). Similar to the previous example, if we gather and utilize your personal information based on our legitimate business interests, we will be transparent with you about those interests at the appropriate time.

Please email us at support@Smart Convo.com if you have any queries or would like more information regarding the legal basis upon which we collect and use your personal information.

10. FOR CALIFORNIA RESIDENTS

California residents have the right to request in writing from companies with whom they have an established business relationship (a) a list of the categories of personal information, such as name, e-mail and mailing address, including billing ZIP code and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities). This right is granted by California's Shine the Light law, Cal. Civ. Code 1798.83. Please email us at support@SmartConvo.com if you would like the aforementioned details. Following receipt of such requests for information access at the e-mail or postal addresses shown below, we shall answer within 30 days. Please be aware that we must only answer to each person once each calendar year.

In addition, California law mandates that we disclose whether we respect your browser's "Do Not Track" settings with regard to targeted advertising. Currently, we do not change our procedures in response to a Do Not Track signal. Please visit www.aboutads.info/choices to learn more about Do Not Track and how to choose not to receive targeted advertising.

Moreover, California residents have the following rights to any personal information we may hold about them, subject to certain exceptions:

 

(i) Requests to Know

You have the right to request that we disclose:

  • The form of personal data about you that we have collected;

  • The types of personal data about you that we have marketed or shared with third parties for commercial gain;

  • Types of sources from which we have gathered your personal information;

  • The economic or business goals behind selling or gathering your personal data;

  • The categories of third parties to whom the personal information was sold, by category of personal information, for each party to whom personal information was sold, and the categories of personal information about you that has been sold or shared, if any;

  • The precise elements of personal information gathered.

You can send a request to support@SmartConvo.com for more information. Our response may be sent electronically or via postal mail. More than twice in a calendar year, we are not compelled to reply to requests for information.

We don't sell personal information on California citizens, and we haven't in the last 12 months either. As a result, we have removed the "Do Not Sell My Personal Information" link from our website. If our procedures change, we will amend this privacy statement and take additional legal action as required.

(ii) Requests to Delete

You have the right to ask us to remove any personal information we may have about you. Unless otherwise required or permitted by law, we shall comply with a verified request to erase personal information. Email requests to erase personal data should be sent to support@SmartConvo.com.

(iii) Authorized Agents

An authorized agent of your choosing may submit requests on your behalf. We may ask that you authenticate your identification directly with us, and you must give us written consent before allowing an authorized agent to submit a request on your behalf. Alternately, a request may be made on your behalf by an authorized agent who has been granted power of attorney in accordance with Probate Code sections 4000-4465.

(iv) Methods for Submitting Consumer Requests and Our Response to Requests

You can send an email to privacy@Smart Convo.com with requests for access and requests to have personal information about you deleted.

 

In order to confirm your identification, we might need more information from you after receiving a request. Any further details you provide will only be used to confirm your identity and won't be used for any other reason.

Within ten (10) business days of receiving your request, we will acknowledge it. We will respond to your request within 45 calendar days of receiving it, pending our ability to confirm your identification. If we need longer time (up to 90 days), we will write to let you know why and for how long. We confirm your request via email in order to maintain the protection of your personal information and your right to privacy.

Any disclosures we offer will only cover the 12-month period before the receipt of the verifiable consumer request. If appropriate, we will additionally explain in our response why we are unable to fulfill a request.

Except in cases when your verifiable consumer request is excessive, repeated, or obviously baseless, we don't charge any fees to process or respond to it. Before executing your request, we will let you know why we think the request is justified in charging a fee and provide you an estimate of the cost.

(v) The Right to Non-Discrimination

Your right to utilize your above-described California privacy rights without facing discrimination is guaranteed. If the California Consumer Privacy Act does not allow it, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

11. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be amended as necessary to reflect evolving judicial, technological, or commercial events. Depending on the importance of the changes we make, we will take the proper steps to notify you when we update our privacy policy. If and where this is mandated by applicable data protection legislation, we will ask for your permission before making any significant changes to the Privacy Policy.

You can see when this Privacy Policy was last updated by checking the “Last Updated” date displayed at the top of this Privacy Policy. The new Privacy Policy will apply to all current and past users of the website and will replace any prior notices that are inconsistent with it.

12. HOW TO CONTACT US

If you have any questions or concerns regarding our privacy policies, please send us a message with the subject line “Questions about Privacy Policy” to support@SmartConvo.com.