Privacy Policy

1. Controller

Controller within the meaning of the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679):

SMARTNETYX LTD
Gladstonos 12-14, Paphos 08046, Cyprus
Registration number: HE 479019
Represented by: Milan Oesert (Director)
Email: contact@smartnetyx.com
Phone: +357 95956591

2. Principles of data processing

We collect and process personal data only to the extent necessary to provide our services or if you have expressly consented. Legal bases are Art. 6 para. 1 lit. a (consent), lit. b (contract performance), and lit. f GDPR (legitimate interest).

3. Hosting

This website is hosted by Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA). When the website is accessed, server log files are automatically recorded (IP address, date/time, URL accessed, browser). This data is processed to ensure operations and deleted after 30 days at the latest. Vercel is certified under the EU-US Data Privacy Framework (DPF).

4. Contact form

When you use the contact form, we process:

• Name (required)
• Email address (required)
• Company (optional)
• Message

Purpose: Answering your enquiry. Legal basis: Art. 6 para. 1 lit. b GDPR (pre-contractual measures). Storage location: Supabase (EU region). Retention period: 2 years, unless a longer statutory retention obligation exists.

5. Newsletter

For newsletter distribution, we process your email address and optionally your name. Registration uses a double opt-in procedure. Legal basis: Art. 6 para. 1 lit. a GDPR (consent). You can unsubscribe from the newsletter at any time — every email contains an unsubscribe link.

Emails are sent via Resend (Resend Inc., San Francisco, USA). Data transfer to the USA: EU-US Data Privacy Framework.

6. Appointment booking

We use Cal.com (Cal.com, Inc., San Francisco, USA) for appointment bookings. When booking, your name and email address are transferred to Cal.com. Legal basis: Art. 6 para. 1 lit. b GDPR. Data transfer to the USA: EU-US Data Privacy Framework.

7. Web analytics (Plausible Analytics)

We use Plausible Analytics (Plausible Insights OÜ, Tallinn, Estonia) for privacy-friendly analysis of website traffic. Plausible sets no cookies, stores no personal data, and does not collect IP addresses. All data is aggregated and anonymised. Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest).

8. Data processing in the course of our services

In the course of our consulting and IT services, we use the following tools that may process personal data:

Legal basis for processing in the course of services: Art. 6 para. 1 lit. b GDPR (contract performance) or Art. 6 para. 1 lit. f GDPR (legitimate interest).

9. Academy-specific data processing

For participants of the SMARTnetyx Power Platform Academy, we additionally process: company name, contact person, VAT ID, submitted use cases, progress data in the Teams community, and video testimonials where applicable.

Video testimonials are stored on Supabase (EU region) and published on the website and on social media. Publication is based on the consent given in the Academy Terms and can be revoked at any time with 30 days’ notice.

10. Data processing agreements

We have concluded data processing agreements (DPA) with the above-mentioned providers or conclude them as needed. If the Contractor gains access to the client’s personal data in the course of services (e.g. tenant administration), a separate DPA pursuant to Art. 28 GDPR is concluded.

11. Retention periods

Personal data is deleted as soon as the purpose of processing ceases, unless statutory retention obligations apply.

12. Your rights

You have the following rights regarding your personal data:

• Access to your stored data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure of your data (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Objection to processing (Art. 21 GDPR)
• Withdrawal of consent (at any time, without giving reasons)

To exercise your rights, please contact: contact@smartnetyx.com

You also have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority responsible for SMARTNETYX LTD is: Commissioner for Personal Data Protection, Cyprus (dataprotection.gov.cy).

13. Information for persons in the USA (CCPA/CPRA)

If you are a resident of California or another US state with comparable data protection legislation, you have additional rights:

• Right to Know: You may request information about the categories and specific personal data we collect about you.
• Right to Delete: You may request the deletion of your personal data.
• Right to Opt-Out: We do not sell personal data or share it for targeted advertising. A “Do Not Sell” opt-out is therefore not required.
• Right to Non-Discrimination: The exercise of your data protection rights will not result in discrimination.

Please direct requests to: contact@smartnetyx.com. We will respond within 45 days.

14. Cookies

This website uses only technically necessary cookies (e.g. for language settings). No tracking cookies or advertising cookies are used. A cookie consent banner is therefore not required.

15. SSL/TLS encryption

This website uses SSL/TLS encryption for all data transfers for security reasons.

16. Changes to this privacy policy

We reserve the right to amend this privacy policy to adapt it to changes in the legal situation or changes to our services. The current version is always available at smartnetyx.com/legal/privacy.