Data Security and Privacy Policy
This Data Security & Privacy Policy applies to all personal identifiable information (“Personal Data”) we collect and process. It covers what we collect and how we use, disclose, transfer, and store Personal Data as well as your rights to this information. We value your privacy and observe due care in processing and protecting Personal Data. We recommend you read this Policy carefully.
We process Personal Data through the Smardaten websites, applications (“Smardaten Sites”) and services. By voluntarily using the Smardaten Sites and services, and/or providing data or other information via the Smardaten Sites and services, you are indicating your consent to this Privacy Policy and agree to be bound by its terms.
Who we are
All tasks and responsibilities concerning data protection are covered by our security and data privacy teams. You may submit inquiries regarding personal data protection, privacy and security matters or contact us for other reason via bd@njsdata.com. You can call us on 0044-(0)-772-555-4626.
Scope
The scope of this Privacy Policy includes the collection of Personal Data through:
· The website available at www.smardaten.net, and other web sites form which you are accessing this Privacy Policy (e.g., Community Portal, Documentation pages, Developer Account pages, event pages);
· Our social media pages located at [ https://www.linkedin.com/company/smardaten-technologies-co-ltd, etc] (collectively, our “Social Media Pages”);
and
· HTML-formatted email messages and polls that we send to you and that link to this Privacy Policy;
and applies to all visitors/users of the Smardaten Sites and services, and our Social Media Pages.
Personal data
You may visit the Smardaten Sites anonymously, without telling us who you are and without revealing any information about yourself. There are times, however, when we may need certain Personal Data from you.
You may choose to provide us with Personal Data (such as your name, email address and company name) through the Smardaten Sites when you elect to register with Smardaten in order to download our trial products or access premium content, or to make use of the Smardaten Platform as community member or developer. When you provide Personal Data in order to register with Smardaten, such Personal Data will be used in order to provide you with access to the requested products, services, content and/or information. We may also use Personal Data to help us understand who is using our products and services, to support you in the development as community member or developer and optimizing the use of the Smardaten Platform, and to help us manage business development activities.
What we collect as Personal Data and Why
We may collect your Personal Data in the following categories with reasons to follow:
l Identification, contact, and employment information, including your full name, professional email address, professional postal address, professional telephone number, company name, job title or area of expertise, country of location, username and password.
The reasons why we collect them:
l Establish and manage our relationship with our customers, service providers, distributors and other partners,
l Manage, operate, and maintain the products or services we provide to you or receive from you (or your employer), including to schedule meetings and calls, send technical notes, documentation, statements and invoices, address inquiries and complaints, provide information about available updates of our products, send security alerts when necessary, and determine eligibility to use our products or services.
l Inform you of our products, services, offers, events and webinars that we believe may be of interest to you, through means of communication such as e-mails, marketing newsletters, telemarketing calls, and SMS, as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent, when required by law. Notably, if you purchase our products or services, we may communicate with you to inform you about similar products or services. You may opt-out from such communications at any time by clicking on the link at the bottom of our marketing e-mails, or by updating your Communication Preference.
If you visit our premises, to prevent unauthorized access to our premises, protect the health and safety of our staff and visitors, and to detect and prevent fraud, criminal behavior or misconduct on our premises.
Marketing preferences as set out in your Communication Preference Center, including the contact information you would like Smardaten to use for marketing purposes, your marketing content preferences, and whether you opted out of our marketing communications.
The reasons why we need to collect them：
Manage your preferences in terms of communications you receive from Smardaten, and to provide you with content adapted to your preferences.
Comply with laws and regulations restricting marketing communications.
Communication information: when you are communicating with a Smardaten staff member, for example by email, phone, or by completing an online form or participating in online chat or forum, in the context of a support case, for an inquiry, or to register to a Smardaten event or webinar. We will record the content of the communication, including your comments and opinions, as well as the date and time of the communication, and the medium used to send it.
The reasons why we need to collect them:
Address your requests, comments, issues, questions, or concerns
Improve our interactions with you and better meet your expectations, notably in the context of support cases
Determine the products and services that may be of interest to you and to send you communications in accordance with your interest
Prevent fraud and phishing attacks targeting Smardaten or members of Smardaten staff by assessing whether we are communicating with genuine contacts and not malicious parties.
Information shared on Smardaten Community: if you register for our online Community, we may ask you to provide a username, as well as other biographical information, such as your occupation, location, social media profiles, company name, areas of expertise and professional interests.
The reasons why we need to collect them：
Our website hosts Smardaten Community, a forum dedicated for questions and discussion around our products and services. Any personal information that you choose to submit via this forum may be read by us, or by others who visit this forum.
Payment and transaction information, including information such as the service level purchased, date and time of your transaction, and payment information, such as your credit card or bank account details.
The reasons why we need to collect them：
Facilitate transactions, detect and prevent fraud and inform our advertising and marketing.
Information that we obtain from third party sources
From time to time, we may receive some of the personal information listed in this notice from third party sources, including from your employer or the company you are affiliated with, third party suppliers from which we purchase personal information, and partners, including partners of our Technology Alliance Program, Value Added Resellers, and co-organizers and sponsors to Smardaten events and webinars.
We may combine the information we received from third-party sources with personal information provided by you, or that we automatically collect about you (see table below). This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising about the products and services that may be of interest to you. If you believe that your personal information has been provided to us by a third party improperly, or want to exercise your rights relating to your personal information, please contact us at bd@njsdata.com.
We may also collect some of the personal information listed in this notice through social media platforms, such as Facebook, LinkedIn, or Twitter. This personal information is the information that you choose to make publicly available on these platforms, and may include your name, email address, and other biographical information such as job title , company name, area of expertise and professional interests.
Smardaten may also acquire your personal information in the course of mergers and acquisitions of another company or business.
Information that we collect automatically
Usage data relating to the access and use of our cloud products or services, including: login information, such as IP address, login credentials, date and time of access, country of location, browser version, days active, time on site;
type of license and product used, features used, buttons clicked on the interface, jobs performed, debug run;
support information, including error messages, configurations issues, and support case reported.
The reasons why we collect them:
l Monitor subscriptions to our products and services, including to ensure that only licensed users use our software and to determine relevant subscription fees due based on numbers of licensed users , to review compliance with applicable usage terms, and to maintain the security of our products and services.
l Understand, assess, and improve the usage, performance, and enjoyment of our products and services, as well as engagement with our products and services, customers and users experience, and capacity requirements, including to determine the products and services that may be of interest to you for marketing purposes.
l Products and services development and enhancement, notably to identify future opportunities for development of our products or services, to develop new features or functionalities, to identify customers and users opportunities, and to provide users with more pertinent advertisements, content or features.
Information about your device, including information about the computer, tablet, smartphone or other electronic device you use to connect to our products and services. This information can include details about the type of device, unique device identifying numbers, operating systems and applications connected to our products and services through the device.
The reasons why we collect them:
We use information about how you use and connect to our products and services to present our products and services to you on your device and to determine products and services that may be of interest to you for marketing purposes.
Information collected through cookies, such as your geographic location, and the links clicked on our websites.
The reasons why we collect them:
We use various cookies to ensure the functioning of our websites, and to help us understand how our websites are being used or how effective our marketing campaigns are. For more information about cookies, and how to disable them, please see our Cookie Policy.
Information collected through automatic data collection tools during your visit of our websites and domains (“Website”) or use our products or services, including:
Internet Protocol (IP) addresses,
clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with the Website),
certain standard information that your browser sends to our Website, such as browser type and language, access times, and the address of the website from which you arrived on our Website Collecting this information enables us to better understand the visitors who come to our Website or use or products and services, where they come from, and what content is of interest to them.
The reasons why we collect them:
We use this information to analyze overall trends, to improve the quality and relevance of our Website, products, and services, and to secure and maintain our systems. This information also helps us understand marketing campaign effectiveness.
How we collect Personal Data
We may collect your Personal Data:
· When you contact us with your questions, comments, ideas, complaints, or communicate with Smardaten (including when applying for employment with Smardaten): we may collect various information, depending on the manner in which you contact us (e.g., if you send us an email, we will collect your email address; if you solicit for a job, we will collect your details as provided in your application) and the reason for contacting us. In any case, we will collect your contact details to be able to respond and further communicate with you.
· When you submit a support ticket with Smardaten: we will collect your email address so we can respond to your report. You will also need to describe the problem that you have experienced with our services so we can take care of it.
· When you visit the Smardaten Sites: Smardaten may also collect certain data from your computer and internet connection, including the IP address of your computer, the date and time you accessed our web sites, the internet address of web sites from which you link to the Smardaten Sites, the device you are using (such as laptop or tablet) and your movements and preferences on the Smardaten Sites.
· When you sign up to use the Smardaten Platform: When you participate in the Smardaten Platform as community member or developer we will collect Platform Usage statistics and analytics that consist of Personal Data (such as your name, email address, company, certification, platform activities).
· When you subscribe to a course or training with the Smardaten Academy: We collect your first and last name, your email address, your telephone number, the region, and the name of the company you work for.
· When you attend a webinar or an online event of Smardaten: We collect your first name, last name, your email address, company name, the country, and the area of focus.
· From other sources: we may receive Personal Data from other sources, marketing partners, social media platforms, talent acquisition partners, from your co-workers and friends, as well as from other third parties. We also may receive data from publicly available sources by data enrichment services.
· Offline: we may collect Personal Data about you offline, such as when you attend one of our events or visit our exhibition booths by scanning your badge or call our customer service representatives.
If you submit any Personal Data relating to other people to us in connection with our services or talent acquisition, you consent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.
Invitations to Smardaten Platform
If you choose to invite another person to a Smardaten Platform account or project, we will ask you for the name and email address of that person. We will automatically send that person an invitation email to visit the Smardaten Sites, to create an account or join the project. Smardaten stores this information for the sole purpose of sending the email and tracking the success of our referral program.
Blog/Forum
If you use our blog, forum or marketplace on the Smardaten Sites, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these blogs and forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these blogs and forums.
Statistical Information
We collect information from visits to the Smardaten Sites to help us provide a better experience, service and to make the Smardaten Sites as user friendly and purposeful as possible. For example, we keep track of the domains from which people visit and we also measure visitor activity on the Smardaten Sites. However, when we do so, we do so in ways that keep the information anonymous.
Smardaten may use this data to analyze trends and statistics and to help us provide better user experience and service. None of the information described in this paragraph is reviewed at an individual level.
Links to Other Web Sites
The Smardaten Sites may contain links to other web sites. Smardaten is not responsible for the privacy practices or the content of such web sites. The links from the Smardaten Sites to other web sites do not imply that Smardaten endorses or has reviewed the third-party web sites. We suggest contacting the operators of those websites directly for information on their privacy policies.
Platform Usage Analytics
We collect information from visits to the Smardaten Platform to help us and our community members, developers and customers to provide a better experience, service and give insight to developments. This analysis, statistics and other data generated by your use of the Smardaten Platform may be disclosed with your team members.
Use of Personal Data
We use Personal Data only when we are allowed to by law and only for particular reasons, we collected. Most commonly, the reasons are the performing of a contract with you or your employer, the consent you gave to us, when it is necessary for our legitimate interests (and your interests and rights don’t override ours), and when we need to comply with legal or regulatory obligations.
We may use Personal Data:
· To log ( with SSO) you onto the Smardaten Sites;
· To manage our relationship with you, such as your registration to our events or as a customer;
· Providing you with the products and services you have requested;
· To respond to your inquiries and fulfill your requests;
· To send administrative information to you, such as the services and changes to our terms, conditions and policies;
· To allow you to send messages to your connections through the services;
· To send marketing communications that may be relevant to you;
· For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving and modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
· To understand your use of the Smardaten Platform as community member or developer;
· To support you as developer in your professional or personal tasks, your training and the development on your projects;
· To support your team on the projects your team is working on;
· To allow you to participate in prize draws, competitions and promotional activities and to administer these activities (some of these activities have additional rules, which could contain additional information about how we use, so we suggest that you read these rules carefully);
· To facilitate social sharing functionality; and
· As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and those of any of our affiliates; (f) to protect our rights, privacy, safety and property, and that of our affiliates, you and others; and (g) to allow us to pursue available remedies and limit the damages that we may sustain.
We may use Personal Data for compatible purposes if we think we need to do so.
Legitimate interest
For any uses on the basis of legitimate interest, we have conducted a legitimate interest assessment to ensure that such processing isn’t overridden by your rights or interests.
Developing the Smardaten Platform: We use aggregated and personal data about your use of the Smardaten Platform and services to develop the platform. These activities are necessary to fulfil our interest in creating a better platform and helping us create better technology and better communications.
Share Personal Data
Smardaten is not in the business of selling Personal Data. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share Personal Data with certain third parties without further notice to you, as set forth below:
· Smardaten, like many businesses, sometimes hires other companies to perform certain business-related functions, such as web site hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, processing payments, and other similar services. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
· By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages). Please note that any information you post or disclose will become public information and may be available to users of the Smardaten Sites and services, and our Social Media Pages, and to the general public. We urge you to be very careful when deciding to disclose any information about youself.
· To your connections associated with your social media account, to other web site users, as well as to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Smardaten account or log into your Smardaten account from your social media account. By connecting your Smardaten account and your social media account, you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media site’s Privacy Policy. If you do not want Personal Data about you shared with other users or with your social media account provider, please do not connect your social media account with your Smardaten account and do not participate in social sharing on the Smardaten Sites and services.
· Smardaten may share your registration data for an event of Smardaten with Partners of Smardaten who are listed on the registration page, The Partners will use your registration data for the purposes of their participation in the event. If a Partner intends to use your personal data for any other purposes, they will contact you to explain how and for which other purposes they will use your registration data.
· In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) we may disclose Personal Data to a third party.
· As we believe to be necessary or appropriate we may also disclose Personal Data to a third party: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and those of any of our affiliates; (f) to protect our rights, privacy, safety and property, and that of our affiliates, you and others; and (g) to allow us to pursue available remedies and limit the damages that we may sustain.
Security
Personal Data related to you is treated as strictly confidential and we have taken appropriate technical and organizational security measures against loss and unlawful processing of such information. To protect the Personal Data about you against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we use adequate physical, technical and organizational security measures. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately about the problem by contacting us.
Cookies
Cookies are small snippets of text saved on your computer or mobile device that distinguish you from other users. Like most websites, Smardaten Sites use cookies. Only the strictly necessary cookies are active. These cookies do not collect personal information. By visiting Smardaten Sites for the first time you can activate other cookies, such as targeting cookies or performance cookies. These cookies will be stored on your device. For more details about Smardaten Cookie Policy, please visit Smardaten Cookie Policy Page.
Your Rights
If you tell us that you do not want us to use Personal Data as a basis for further contact, we will respect your wishes. Regarding our use of the Personal Data about you, you can exercise a variety of the rights, such as:
· Request access to the Personal Data we have about you;
· Ask us to erase Personal Data we have about you;
· Object any processing we do on the basis of legitimate interests;
· Ask us to restrict the processing of Personal Data about you;
· Ask us to correct any incorrect Personal Data we have about you. If you are a registered to the Smardaten Sites as user, you may review and update this information at any time through the account page.
As noted above, you can log into your profile setting on the Smardaten Sites and view, change or replace your own profile data. If you want to exercise any of the foregoing rights or have any other question regarding the Personal Data related to you, please contact us at: bd@njsdata.com.
In your request, please let us know what limitations you would like to put on our use of Personal Data related to you. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note also that we may need to retain certain information for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
Retention
Unless indicated otherwise at the time of the collection of Personal Data about you (e.g. within a form completed by you), we erase the Personal Data if the retention of that data is no longer necessary for the purposes for which they were collected or otherwise processed, or to comply with legal obligations (such as retention obligations under tax or commercial laws).
Transfer of Personal Data
Personal Data are guaranteed be stored on servers located within the European Economic Area and UK/Ireland, and may also be processed in any country where we have facilities or in which we engage service providers.
In the event that we transfer Personal Data about you outside the European Economic Area (such as US), we ensure that this Personal Data is protected in a manner which is consistent with the General Data Protection Regulation.
Changes to Our Privacy Policy
We may change our business and the Smardaten Sites from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice. We recommend that you review this Privacy Policy regularly, so that you remain informed of any changes. Your continued use of the Smardaten Sites after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised notice.
This Privacy Policy was last updated on 18th May 2022
