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Privacy Policy - Smartnetyx Ltd.

Privacy Policy

Last updated: December 2024

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.


Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the imprint of this website.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may be data that you enter into a contact form, for example.

Other data is collected automatically or after your consent when you visit the website through our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.


2. Controller

The controller responsible for data processing on this website is:

Smartnetyx Ltd.
Gladstonos 12-14
Paphos 08046
Cyprus

Represented by: Milan Oesert (Director)
Email: contact@smartnetyx.com
Phone: +357 95956591

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (e.g., names, email addresses, etc.).


3. Storage Duration

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will take place after these reasons cease to apply.


4. Your Data Subject Rights

You can exercise the following rights at any time using the contact details provided:

  • Information about your data stored with us and its processing (Art. 15 GDPR),
  • Correction of inaccurate personal data (Art. 16 GDPR),
  • Deletion of your data stored with us (Art. 17 GDPR),
  • Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 GDPR),
  • Objection to the processing of your data with us (Art. 21 GDPR) and
  • Data portability, provided you have consented to data processing or have concluded a contract with us (Art. 20 GDPR).

If you have given us consent, you can revoke it at any time with effect for the future.

You can lodge a complaint with the competent supervisory authority at any time. Your competent supervisory authority depends on the state of your residence, your work, or the alleged violation. A list of supervisory authorities (for the non-public sector) with addresses can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html


5. Data Collection on This Website

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Hostname of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of their website – for this purpose, server log files must be recorded.


Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.

The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after completion of your inquiry). Mandatory legal provisions – in particular retention periods – remain unaffected.


Inquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.

The data sent to us via contact inquiries will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after completion of your request). Mandatory legal provisions – especially legal retention periods – remain unaffected.


6. Analysis Tools and Advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, duration of stay, operating systems used, and origin of the user. This data is assigned to the respective end device of the user. An assignment to a user ID does not take place.

Furthermore, with Google Analytics we can record your mouse and scroll movements and clicks, among other things. Google Analytics also uses various modeling approaches to supplement the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TTDSG. Consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/

Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

More information about handling user data with Google Analytics can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Data Processing Agreement

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.


7. Plugins and Tools

Clockify (Time Tracking)

We use Clockify for internal time tracking and project management. The provider is CAKE.com Inc., 1001 Bannock Street, Denver, CO 80204, USA.

Clockify does not process any personal data of website visitors. Time tracking is exclusively internal for employees and projects.

More information can be found in Clockify's privacy policy: https://clockify.me/privacy

Canva (Design Tool)

We use Canva to create graphics and marketing materials. The provider is Canva Pty Ltd, 110 Kippax St, Surry Hills NSW 2010, Australia.

Canva does not process any personal data of website visitors. Use is exclusively internal.

More information can be found in Canva's privacy policy: https://www.canva.com/policies/privacy-policy/


8. Microsoft Services (Azure, Power Platform)

We use Microsoft Azure and the Microsoft Power Platform to provide our services. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.

The processing of personal data in the context of our services is based on Art. 6(1)(b) GDPR (contract fulfillment) or Art. 6(1)(f) GDPR (legitimate interest).

Microsoft processes data in data centers within the EU. For data transfers outside the EU, the EU standard contractual clauses apply.

Details on data protection at Microsoft: https://privacy.microsoft.com/en-us/privacystatement


9. Data Processing

We have concluded or will conclude data processing agreements (DPA) with the above-mentioned providers as needed. These are contracts required by data protection law that ensure that they only process the personal data of our website visitors according to our instructions and in compliance with the GDPR.


10. Cookies

Our website uses so-called "cookies". Cookies are small text files and do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or automatic deletion is performed by your web browser.

In some cases, cookies from third-party companies may also be stored on your device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g., cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions you have requested (e.g., for the shopping cart function), or to optimize the website (e.g., cookies for measuring web audiences) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of their services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TTDSG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.


11. SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.


12. Objection to Advertising Emails

We hereby object to the use of contact data published as part of the imprint obligation for sending unsolicited advertising and information materials. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, such as through spam emails.

Source: Created with support from eRecht24 and adapted for Smartnetyx Ltd.