SmartNotify™, PyraSolutions LLC and its group companies (“SmartNotify”, “we”, “us” and “our”) respect your privacy. This Notice describes our privacy practices regarding the collection, use, and disclosure of your information through the SmartNotify™ web site, our products, online services, apps, and other services we provide both online and offline (collectively referred to as “SmartNotify™ Services”), along with our marketing and advertising practices. We also cover some basic terms of service

Some Services use cookies and similar technologies to access or store information.

CONTENTS

1.     INFORMATION COLLECTION
Personal Information We May Collect
Other Information We May Collect

2.     INFORMATION USE AND DISCLOSURE
How We May Use and Disclose Personal Information
How We May Use and Disclose Other Information

3.     THIRD-PARTY SERVICES

4.     THIRD-PARTY ADVERTISERS

5.     SECURITY

6.     MARKETING PREFERENCES

7.     HOW YOU CAN MANAGE YOUR PERSONAL INFORMATION 

8.     RETENTION PERIOD

9.     USE OF SMARTNOTIFY SERVICES BY MINORS

10.   INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

11.   CONTACT US

12.   UPDATES TO THIS PRIVACY NOTICE

13. PAYMENTS

 

1. INFORMATION COLLECTION

Personal Information We May Collect

SmartNotify may collect various types of personal information, including:  

· Personal and business contact information (such as name, postal address for billing and shipping, telephone number, and email address)

· Account ID

· Profile picture

· Social media information

. Geolocation information

. Connected devices

· When taking a payment on SmartNotify, we do not collect your credit card information. This information is solely handled by our credit card clearing house

If you submit any personal information relating to other people, to us or to our service providers, you represent that you have the authority to do so and to permit us to use their personal information in accordance with this Privacy Notice. 

We and our service providers may collect personal information from a variety of sources, including: 

· From you: We may collect personal information you elect to share with us such as your name or preferred means of communication.

· Through the SmartNotify Services: We may collect personal information you provide when you use SmartNotify Services, for example, when you sign up for a newsletter, make a purchase, or use our products or apps.

· Offline:  We may collect personal information you provide to us offline, such as when you visit our stores, attend one of our trade shows, place a verbal order over the phone or contact customer services. 

Other Information We May Collect

SmartNotify may also collect other information from your app, browser or device that does not reveal your (or anyone else’s) real world identity, for example:

· Browser and device information

· App or device usage data

· Information collected through cookies, pixel tags and similar technologies

· IP address

· Location data

· Aggregated, anonymized, or de-identified information

· Demographic information and other information provided by you (i.e., language, occupation, postal code)

We and our third-party service providers may collect this information in a variety of ways, including: 

· Through your browser or device:  Most browsers and devices collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, and the name and version of the SmartNotify Services (such as the app) you are using.  We use this information, for example, to make sure that the SmartNotify Services function properly, analyze the performance of our products, and improve and maintain the SmartNotify Services and products.

· Through your use of a SmartNotify app:  When you download and use a SmartNotify app, we and our service providers may track and collect usage data, such as the date and time the SmartNotify app on your device accesses our servers and what information and files have been downloaded to the SmartNotify app.

· Through cookies and similar technologies:  We use cookies to make our web sites operate, work more efficiently, and provide analytic information. Technologies similar to cookies are also used in connection with some SmartNotify Services, such as pixel tags, web beacons, clear GIFs, JavaScript, and local storage.

· IP Address: IP addresses are automatically transmitted as part of any Internet communication, and collecting IP addresses is a common practice; many web sites, applications and other SmartNotify Services collect IP addresses automatically.  We use IP addresses for purposes such as calculating usage levels of the SmartNotify Services, helping diagnose server problems, security, and administering the SmartNotify Services.

· Location Data:  We may collect the physical location of a connected device, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based SmartNotify Services, content and advertising. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized SmartNotify Services, content and advertising.

 

2. INFORMATION USE AND DISCLOSURE

How We May Use and Disclose Personal Information

We may use personal information:

· To respond to your inquiries and fulfill your requests, such as to send you technical documents or whitepapers.

· To send you communications, such as newsletters, in accordance with your communication preferences.

· To personalize your experience on the SmartNotify Services by presenting content tailored to you.

· To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain more information about how we use and disclose your personal information, so we suggest that you read these rules carefully.

· To allow you to send messages to a friend through the SmartNotify Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s contact information. 

· To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.

· For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, testing, enhancing, improving or modifying our SmartNotify Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. 

· To send administrative information to you, for example, information regarding the SmartNotify Services and changes to our terms, conditions, and policies.

Personal information may be shared or disclosed:

· To our authorized third-party service providers and suppliers who provide services to us such as web site hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services. However, they cannot use your information for any marketing operations.

· To identify you to anyone to whom you send messages through the SmartNotify Services.

· By you, on message boards, forums, chat, profile pages and blogs to which you are able to post information and materials. Please note that any such information you post or disclose will become public information, and may be available to users and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, online.

· To a third party 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).

· As we believe is required, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process and/or to respond to requests from competent 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 physical and SmartNotify’ Intellectual property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

 

3. THIRD-PARTY SERVICES

This Privacy Notice does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not SmartNotify service providers, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure.  This includes:  (a) any third party operating any site or service to which the SmartNotify Services link – the inclusion of a link on the SmartNotify Services does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any personal information you disclose to other organizations through or in connection with the SmartNotify Services or our Social Media Pages. For example, we may use and direct you to a third party payment service to process payments made through the SmartNotify Services.  If you wish to make a payment through the SmartNotify Services, your personal information may be collected by such third party and not by us, and will be subject to the third-party’s privacy policy, rather than this Privacy Notice. 

 

4. THIRD-PARTY ADVERTISERS

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the SmartNotify Services and other web sites, based on information relating to your access to and use of the SmartNotify Services and other web sites.   

 

5. SECURITY

The SmartNotify Services are designed to provide reasonable organizational, technical and administrative measures to protect personal information within our organization against unauthorized or unlawful access, alteration, disclosure or destruction.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  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 have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

 

6. MARKETING PREFERENCES

We give you many choices regarding our use and disclosure of your personal information for marketing purposes.  You may access and update your contact details and communication preferences by using one of the following methods: visit the specific product or service web site; use the contact us form; or send a letter to the postal address below. You may choose to update your communication preferences for the following types of marketing activities:

· To accept or refuse receiving marketing-related emails from us in the future. 

We will comply with your request(s) as soon as reasonably practicable.  Please also note that if you do choose not to receive marketing-related emails from us, we may still send you important administrative messages (i.e., service notifications).

 

7. HOW YOU CAN MANAGE YOUR PERSONAL INFORMATION

If you would like to access, correct, update, or delete the personal information that you have provided to us, you may contact us by: visiting the specific product or service web site using the contact us form; sending an email; or sending a letter to the postal address below including your name, e-mail address, account identification, and purpose of the request.

For your protection, we will only implement requests with respect to personal information about you (not anyone else), and we may need to verify your identity before implementing your request.  We will comply with your request as soon as reasonably practicable and in accordance with applicable law. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).  Some of your information may remain within our systems and other records, in compliance with applicable law.

 

8. RETENTION PERIOD

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. 

 

9. USE OF SMARTNOTIFY SERVICES BY MINORS

The SmartNotify Services are not directed to individuals under the age of thirteen (13), or to minors as otherwise defined in local law or regulation, and do not knowingly collect personal information from these individuals. We request that these individuals do not provide personal information through the SmartNotify Services. However, if you believe that we may have collected personal information from someone under the age of thirteen (13), please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and, if appropriate, delete that information.

 

10. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Like any global company, SmartNotify may transfer your personal information to its parent company in the United States (U.S.), or to any SmartNotify group company worldwide when processing that information for the purposes described in this Privacy Notice. We may also transfer your personal information to our third party service providers, who may be located in a different country to you.

SmartNotify complies with the U.S.-EU and U.S.-Swiss Safe Harbor frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union. SmartNotify has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. While the U.S. may not have data privacy laws that are the same as those in the EU and Switzerland, we will protect the information we receive in the U.S. from the EU and Switzerland in accordance with our Safe Harbor commitments. To learn more about the Safe Harbor Program, please visit http://www.export.gov/safeharbor.

 

11. CONTACT US

If you have questions or concerns about SmartNotify’s privacy practices, you can contact us by email or send a letter to the postal address listed below. Please include your contact information, name of the SmartNotify web site or service, and a detailed description of your request or privacy concern.

SmartNotify Corporation
ATTN: Privacy
100 Chemin du Creytel
38114 Allemont France.

12. UPDATES TO THIS PRIVACY NOTICE

We may change this Privacy Notice. The “Last Updated” section at the top of this page states when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the SmartNotify Services. Your use of the SmartNotify Services following these changes means that you accept the revised Privacy Notice.

If any change may materially affect the privacy of your personal information, we will use reasonable endeavors to notify you in advance and give you a reasonable period of time to object to any changes (which you may do by ceasing to use the SmartNotify Services).

We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use and share personal information.

13. PAYMENTS

If you are using SmartNotify under a payment plan, we have some very basic rules that need to be followed:
. You will need to have credits in your account to send SMS, place or receive calls, or access your telephony options.  Credits can be purchased online or via an order to our sales group.
. Your account needs to be in good standing.  We require that you pay yearly for the SmartNotify service.  You will have a one month grace period during which the service will still be available, on a limited basis.  Passed that period we will suspend your account or delete the content of your account.