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Last Revised: May 10, 2018
1. Our commitment to Privacy
Protecting your privacy and your information is a top priority here at Smart Gadget City. The purpose of this Privacy Policy to explain how your personal and business information that you provide to us (collectively “Information”) is protected, what information is collected and how it is used by Smart Gadget City.
By visiting or using our Website and/or Apps (collectively “Website”), Visitors, Users and Customers (collectively “You”) consent to our collection and use of your Information in accordance with this Privacy Policy and you are accepting the practices described herein. We do not transfer, sell or rent your business information to third parties in any way other than what it is stated in this Privacy Policy.
Along with our business and internal computer systems, the Website is designed to comply with US law as well as the following EU legislation with regards to data protection and user privacy: EU General Data Protection Regulation 2018 (GDPR)
The Website’s compliance with the above legislation means that it is compliant with the data protection and user privacy legislation set out by EU countries and territories as well. If you are not certain about whether the Website is compliant with your own country of residence’s specific data protection and user privacy legislation, please contact our Data Protection Officer (as defined in Section 10) for clarification.
Please note that your access to our Services and Website may be subject to certain third party terms and conditions and privacy policies, including but not limited to third party online storage services and payment providers. You agree that Smart Gadget City is not responsible for any such third party terms and conditions and their use of your Information.
Unless stated otherwise, this Privacy Policy only deals with the use and communication of information collected by Smart Gadget City.
If you are under 16 years of age you must obtain parental consent before using the Website.
Those Privacy Policy provisions are part of our LEGAL.
Capitalized terms in this Privacy Policy have the meanings as set forth in our LEGAL.
2. Information collected
The Website collects the following information (“Personal Information”):
User Registration
Only registered Users have access to the special features of our Services (exclusive discounts, deals and custom feed features). You can register through our Website by filling in the registration form. During the registration process, you have to provide us with the following information:
Your First name
Your Email Address
Your Password
Users have the obligation to state truthfully, accurately and fully your up-to-date Information in the registration process. If your Information is not in compliance with these provisions or if Smart Gadget City has reasonable suspicions that your Information is not in accordance with these provisions, Smart Gadget City has the right to reject your application for registration or to suspend or terminate immediately your Account without prior notice. You agree that you have no right to any compensation for the rejection of your application.
Activity and behavior information
We collect information about your activity and behaviour on the Website, such as your posts of any kind and/or the Products that you submit. We also collect our Visitors’ and Users’ reviews about you.
Post Comments
Should you choose to add a comment to any posts that we have published on our Website or blog, your name and email address will be saved to the Website’s database, along with your computer device’s IP address as well as the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not shared with any of the Third Party Data Processors.
Your comments and their associated personal data will remain on the Website until we decide to 1) remove the comment or 2) remove the blog post. This decision shall fall under Smart Gadget City’s discretion only. Should you wish to have the comment and its associated personal data deleted, please email us at support@smartgadgetcity.com.
NOTE: You are advised to not enter personally identifiable information in the actual comment field of any blog post comments that you submit on our Website.
Correspondence information
If you send us personal correspondence, such as emails or letters or third parties send us correspondence about your activities or postings on our Website, we may store such information in our servers.
Payment Information
To protect you against fraud, unauthorized transactions (such as money laundering), claims and other liabilities, we do not collect credit card information.
We allow our third party payment vendor to collect information for the purpose of collecting fees from our Customers on the Website. We do not have access to the payment information that you provide to our third party payment vendor and this information is subject to the privacy policy of the third party payment vendor. For more information regarding the payment information collected by our third party payment vendor and how it uses this information, please visit their webpages below:
Stripe Privacy Policy – https://stripe.com/us/privacy/
Paypal Privacy Policy – https://www.paypal.com/en/webapps/mpp/ua/privacy-full
Website visitation tracking
Our Website uses google analytics (“GA”) to track our Users’ interaction. We use the data to determine the number of people using our Website, to better understand how they locate and use our web pages. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to Smart Gadget City. GA also records your computer device’s IP address which could be used to personally identify you but Google do not grant us access to this. Google is a Third Party Data Processor.
Contact forms and email links
Should you choose to contact us via the contact form at our contact us page or an email link, none of the data that you provide will be stored in the Website or passed to / be processed by any of the Third Party Data Processors. The data will be compiled into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (also known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography. The email content is then decrypted by our local computers and devices.
You consent to our access to and collection of such information (personally identifiable or not) as described above under Section 2 (collectively “Information”). All the information, described in this Section 2, will be disclosed in accordance with applicable laws and regulations. We do not use your Information in any other context other than the one described in our LEGAL and Privacy Policy.
3. How the Information is used
We use your Information as follows:
– We use your Information in order to resolve disputes; troubleshoot problems; help promote your Product; measure consumer interest in Services; inform you about offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our LEGAL; and as otherwise described to you at the time of collection. At times, we may look across multiple Customers to identify problems or resolve disputes, and in particular we may examine your Information to identify Users using multiple usernames or aliases. We may compare and review your Information for errors, omissions and for accuracy.
– We use your e-mail to send you system e-mails about the functionality of our Website that you cannot opt out from and you will have to receive if you want to use our Website. If you want to stop receiving our system e-mails, you will have to stop using our Services or de-activate your Account by e-mailing us at support@smartgadgetcity.com.
– We use the e-mail that you provided us, in order to send you newsletters and promotions in conjunction with your use of our Services. If you do not wish to receive newsletters you may unsubscribe by clicking the unsubscribe link in the next newsletter you will receive (please see Section 4 below).
– We may use Users’ Information in order to provide benchmark analysis and aggregate statistics to Customers based on the performance of their Products. This particular Information will be anonymized, will not contain personal identification and will not be transferred or sold to third parties in any way or format that identifies you.
– We use Website navigation data to operate and improve the Website (please see Section 2 above). We may also use Website navigation data alone or in combination with your Information to provide aggregated information about Smart Gadget City.
— We do not transfer, sell or rent your Information to third parties for their marketing purposes other than what is stated in this Privacy Policy. We request only the Information that we need to operate our Services and improve our Website’s user experience. We do not use your Information to create any advertising creative.
Use of Information by third parties
– We partner with third-party advertising networks to either display advertising on our Website or to manage our advertising on other Websites. These ad network partners do not collect and do not have access to any Information. They may, however, anonymously track your internet usage.
– We make reasonable efforts to make sure that Users and Customers who use our Services, will use the information available to them solely for our Services’ purposes. However, we can not control their use of that information outside this scope and we are not responsible for such unauthorized uses.
– We share our Customers’ Products’ photos and video with our social media partners for promotional purposes. You consent to this use of your Information. If you would like to opt-out from sharing your Products’ photos and video, please e-mail us at support@smartgadgetcity.com.
– Smart Gadget City reserves its right to share your Information with a third party in case of sale merger, control changes, reorganization or liquidation of the company, its subsidiaries or branches. All actions will naturally be completed in compliance with applicable laws of personal data and privacy.
3. How we save your information
Smart Gadget City is a Spain (SP) company. If you are located outside SP and choose to provide information to us, Smart Gadget City transfers your Information to our servers in the SP. SP may not have the same data protection laws as the country in which you initially provided the Information. When we transfer your Information to SP, we will protect it as described in this Privacy Policy. By visiting our Website or providing Smart Gadget City with your Information, you fully understand and unambiguously consent to this transfer, processing and storage of your Information in SP.
If you post a comment on this Website some your Personal Information will be saved in our database. We are currently working on saving your Personal Information in a pseudonymous fashion. In other words the data would require additional processing using a separately stored key before it could be used to identify an individual.
Server information
This website is hosted by Shopify at a CA-based data center inOttawa, Canada
Information regarding Shopify can be found here.
Third Party Data Processors
We use a number of third parties to process personal data on our behalf (“Third Party Data Processors”). Our Third Party Data Processors are based in the US and to the best of our knowledge, they are EU-U.S Privacy Shield compliant.
4. Newsletter
If you are a registered user at our Website, you may receive daily or weekly newsletters from us. If you subscribe to our newsletter, your e-mail address will be forwarded to our Campaign Monitor, a Third Party Data Processor (as defined above) for marketing purposes.
Your e-mail address shall be saved in Campaign Monitor’s database for as long as we continue to use Campaign Monitor’s services for marketing purposes. You may request removal of your e-mail address from Campaign Monitor’s list. You can do this by using the unsubscribe links included in our newsletter.
5. How your information is protected
– Customers understand and agree that their Information can be accessed by the Visitors and Users of our Website. You further agree that Smart Gadget City and its associated companies may use that Information for marketing and promotional purposes which may be directed to our Users. Although Smart Gadget City makes reasonable efforts to restrict access to the above mentioned information only to our registered Users, Smart Gadget City can not guarantee that other third parties will not, without Smart Gadget City’s consent, gain access to it.
– You may ask Smart Gadget City to remove your Product from the Website and thus disable access to your Information by Visitors and Users at any time. However, you acknowledge that the Visitors, Users and other parties who have previously gained access to your Information may have retained a copy. Smart Gadget City is not responsible for the retention, use or violation of privacy of that information in those instances, or for the use or privacy of that information by any of such parties while it is available on our Website.
– All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.
– We do not make any of your Information available to third parties for their marketing purposes. Smart Gadget’s software runs on individual servers and no data given or collected is shared with other social media platforms. If however, we share your Information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.
– Smart Gadget City uses robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your Information, using both server authentication and data encryption. These technologies help ensure that your Information is safe, secure, and only available to you and to whom you have granted access. Smart Gadget City also implements other advanced technology measures to prevent interference or access from outside intruders.
– All traffic (transferral of files) between the Website and your browser is encrypted and delivered over HTTPS.
– We do not tolerate Spam. To report Smart Gadget City-related spam please contact us at support@smartgadgetcity.com. You may not use our communication tools to send spam or otherwise send content that would violate our LEGAL. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.
– Smart Gadget City does its utmost to secure communications and data storage in order to protect confidentiality of your Information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your Information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.
Data Breaches
We will report any unlawful data breach of the Website’s database or the database(s) of any of our Third Party Data Processors to any and all relevant persons and authorities within 72 hours from the time that we are informed either by our Third Party Data Processor or become aware of via our own technical means of protection and security measures, that Information stored in an identifiable manner has been stolen.
6. Cookies Policy
Smart Gadget Cityis using cookies to improve your experience of our Website.
A cookie is a small text file that is stored in your web browser that allows Smart Gadget City or a third party to recognize you. Cookies might be used for the following purposes: (1) to enable certain functions; (2) to provide analytics; (3) to store your preferences; and (4) to enable ad delivery and behavioral advertising.
Cookies placed by the website you are visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies”. We will ask for your consent before we store any cookies related to our server to your browser.
When you visit or register on our Website, Smart Gadget City trough Shopify’s servers send a “first party cookie” to your computer’s or mobile phone’s web browser in order to determine your location and use the appropriate language for our Services. You can delete these cookies at any time through your web browser settings. Standing alone, cookies do not personally identify an individual. Cookies merely recognize the web browser. Unless an individual chooses to identify himself/herself to Smart Gadget City, such as through registering and opening an Account, individuals remain anonymous to Smart Gadget City.
When you use our Services, a third party may place a number of “third party cookies” in your web browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. Third party companies like analytics companies and ad networks generally use cookies to collect user information on an anonymous basis.
You may also opt out of “third party cookies” by following the instructions provided by each third party in its privacy policy. In specific, we use google adwords, adroll and GA as third party cookies for re-marketing purposes.
GA makes use of cookies, details of which can be found on Google’s developer guides. Our Website uses the analytics.js implementation of GA. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within the Website.
If you have any questions about our Cookie Policy, you may contact us at support@smartgadgetcity.com
7. Legal requests
We cooperate with law enforcement authorities, as well as with other third parties, to enforce laws, intellectual property rights and to prevent fraud. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can, and you authorize us to, disclose your name, e-mail address and website use history, with or without a subpoena. Without limiting the above, we will not disclose your Information to any law enforcement or other governmental officials without a subpoena or court order, except when we believe in good faith that the disclosure of information is necessary to protect our rights, enforce our policies, respond to claims that your use of our Services violates Smart Gadget City’s policies or rights or others, or protect anyone’s rights, property or safety.
8. Consent
By using our Website, you consent to the collection and use of your Information as described in this Privacy Policy and our LEGAL.
9. Links to Other Sites
Our Website contains links to other websites that are not owned or controlled by Smart Gadget City. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Website and to read the privacy policies of each and every website that collects personal information. This privacy policy applies only to information collected by this Website.
10. Data Protection Officer & Data Controller
Data Protection Officer
Sebastian Sheppard
Keros Partners
Phone: +✆ +33 184.883.705
Email: info@kerospartners.com
Data Controller
The data controller of this website is: Keros Partners - Barcelona
11. Changes
If our Privacy Policy procedures change, we will post those changes immediately to our Website. Any such changes will be effective immediately from the time they are posted, unless otherwise stated in the change provision. E-mail notification will be sent to Users and Customers who request it.